city of lathrop sewer system management plan · city of lathrop sewer system management plan ii 5.2...

CITY OF LATHROP

Sewer System Management Plan

March 2018

Table of Contents

City of Lathrop Sewer System Management Plan i

TABLE OF CONTENTS

INTRODUCTION .............................................................................................................. 1 SSMP Requirement Background .................................................................................... 1 Document Organization .................................................................................................. 1 City Service Area and Sewer System ............................................................................. 2

ELEMENT 1: GOALS ....................................................................................................... 4

1.1 Regulatory Requirements for Goals Element ........................................................... 4 1.2 Element 1 Appendix ................................................................................................. 4 1.3 Goals Discussion ....................................................................................................... 4

ELEMENT 2: ORGANIZATION ...................................................................................... 5 2.1 Regulatory Requirements for Organization Element ................................................ 5

2.2 Element 2 Appendix A.............................................................................................. 5

2.3 Organization Discussion ........................................................................................... 5 Department Organization ............................................................................................ 5

Description of General Responsibilities ..................................................................... 6

Authorized Representative .......................................................................................... 6 Responsibility for SSMP Implementation .................................................................. 6

2.4 SSO Reporting Chain of Communication................................................................. 6

ELEMENT 3: LEGAL AUTHORITY ............................................................................... 8 3.1 Regulatory Requirements for Legal Authority Element ........................................... 8

3.2 Element 3 Appendix B .............................................................................................. 8 3.3 Municipal Code ......................................................................................................... 8

Prevention of Illicit Discharges .................................................................................. 9

Proper Design and Construction of Sewers and Connections .................................... 9 Lateral Maintenance Access ....................................................................................... 9

Limit Discharge of FOG and Other Debris................................................................. 9 Enforcement Measures................................................................................................ 9

3.4 Agreements with Other Agencies ........................................................................... 10 City of Manteca Interjurisdictional Sewer Agreement ............................................. 10

ELEMENT 4: OPERATIONS AND MAINTENANCE PROGRAM ............................. 11 4.1 Regulatory Requirements for Operations and Maintenance Program .................... 11 4.2 Element 4 Appendix C ............................................................................................ 11

4.3 Collection System Map Discussion ........................................................................ 12 4.4 O&M Activities ...................................................................................................... 12

Sewer Cleaning and Manhole Inspection ................................................................. 13

Lift Station Inspection............................................................................................... 13 Air/Vacuum Release Valves (ARVs) Condition ...................................................... 14

Force Mains to CTF and MWQCF ........................................................................... 14 Pipeline Inspection .................................................................................................... 14 Investigation of Customer Complaints ..................................................................... 14

4.5 Rehabilitation and Replacement Plan ..................................................................... 15 4.6 Training ................................................................................................................... 15

4.7 Equipment and Replacement Parts ......................................................................... 16 ELEMENT 5: DESIGN & PERFORMANCE PROVISIONS ......................................... 17

5.1 Regulatory Requirements for Design & Performance Provisions .......................... 17

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City of Lathrop Sewer System Management Plan ii

5.2 Element 5 Appendix ............................................................................................... 17

5.3 Design & Performance Provisions Discussion ....................................................... 17

ELEMENT 6: OVERFLOW EMERGENCY RESPONSE PLAN .................................. 18 6.1 Regulatory Requirements for Overflow Emergency Response Plan Element........ 18 6.2 Element 6 Appendix D............................................................................................ 18 6.3 Overflow Emergency Response Plan...................................................................... 19

Overflow Detection ................................................................................................... 19

Initial Response ......................................................................................................... 19 Recovery and Clean-up (Mitigation) ........................................................................ 19 Public Access and Warning ...................................................................................... 20 Water Quality Sampling and Analysis ...................................................................... 20 Investigation and Documentation ............................................................................. 20

Regulatory Notification and Reporting ..................................................................... 20

Equipment ................................................................................................................. 21 Training ..................................................................................................................... 21

ELEMENT 7: FATS, OILS, AND GREASE (FOG) CONTROL PROGRAM .............. 22

7.1 Regulatory Requirements for FOG Control Element ............................................. 22 7.2 Element 7 Appendix E ............................................................................................ 22 7.3 FOG Control Discussion .................................................................................... 23

Identification and Sewer Cleaning ............................................................................ 23 Legal Authority ........................................................................................................ 24

Facility Inspection ..................................................................................................... 24 Public Outreach ......................................................................................................... 24

ELEMENT 8: SYSTEM EVALUATION AND CAPACITY ASSURANCE PLAN ..... 25

8.1 Regulatory Requirements for Capacity Management ............................................. 25 8.2 Element 8 Appendix F ............................................................................................ 25

8.3 Capacity Evaluation ................................................................................................ 26 Existing and Future Wastewater Generation ............................................................ 26

Design Criteria .......................................................................................................... 28 Hydraulic Model ....................................................................................................... 28

Capacity Evaluation Results ..................................................................................... 29 8.4 Recommended Capacity Projects ........................................................................... 29 8.5 CIP Schedule ........................................................................................................... 29

8.6 Financial and Economic Analysis ........................................................................... 30 ELEMENT 9: MONITORING, MEASUREMENT, & PROGRAM MODIFICATIONS

.......................................................................................................................................... 31

9.1 Regulatory Requirements for Monitoring, Measurement, & Program

Modifications ................................................................................................................ 31

9.2 Element 9 Appendix G ....................................................................................... 31 9.3 Monitoring and Measurement Discussion.......................................................... 31 9.4 SSMP Modifications .......................................................................................... 33

ELEMENT 10: SSMP PROGRAM AUDITS .................................................................. 34 10.1 Regulatory Requirements for SSMP Audits ................................................... 34

10.2 Element 10 Appendix H ................................................................................. 34 10.3 SSMP Audits Discussion ................................................................................ 34

ELEMENT 11: COMMUNICATION PROGRAM ......................................................... 35

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City of Lathrop Sewer System Management Plan iii

11.1 Regulatory Requirements for Communication Program ................................ 35

11.2 Element 11 Appendix I ................................................................................... 35

11.3 Communication Program Discussion ................................................................... 35

List of Tables, Figures and Appendices

City of Lathrop Sewer System Management Plan

List of Abbreviations and Acronyms

ADWF Average Dry Weather Flow

ARV Air/Vacuum Release Valves

Cal OES California Office of Emergency Services

CCTV closed circuit television

CIP capital improvement project

CIWQS California Integrated Water Quality System

CLSP Central Lathrop Specific Plan

CTF Consolidated Treatment Facility

d/D depth to diameter

FOG Fats, Oils and Grease

FSE Food Service Establishment

GIS geographical information system

gpd/du gallons per day per dwelling unit

gpd/ac gallons per day per acre

GWDR General Waste Discharge Requirements

I&I infiltration and inflow

I-205 Interstate 205

I-5 Interstate 5

IPP Industrial Pretreatment Program

IWRMP Integrated Water Resources Master Plan

LMC Lathrop Municipal Code

LRO legally responsible official

LS lift station

MRP Monitoring and Reporting Program

MWQCF Manteca Water Quality Control Facility

NPDES National Pollutant Discharge Elimination System

O&M Operations & Maintenance

OERP Overflow Emergency Response Plan

OPC Opinion of Probable Cost

POTW publicly owned wastewater treatment plant

PS pump station

PWD Public Works Department

PWWF Peak Wet Weather Flow

RWQCB Regional Water Quality Control Board

SCADA Supervisory Control and Data Acquisition

SLSP South Lathrop Specific Plan

SR-120 State Route 120

SSMP Sewer System Management Plan

SSOs sewer system overflow

SSS WDR Sanitary Sewer Systems Waste Discharge Requirements

SWRCB State Water Resources Control Board

VWNA Veolia Water, North America

WWSMP Wastewater System Master Plan


City of Lathrop Sewer System Management Plan i

List of Tables Table 2-1. Officials Receiving Immediate Notification of SSO

Table 4-1. Routine Inspection of Key Collection System Components

Table 8-1. Wastewater Flow Factors

Table A-1. Names and Telephone Numbers of Staff Responsible for SSMP

Table A-2. List of Staff Responsible for SSMP Elements

Table C-1. Summary of Wastewater Lift and Pump Stations

Table E-1. List of Food Service Facilities in Lathrop

Table F-1. Existing Wastewater Flow by Development Area

Table F-2. Projected Wastewater Flow by Development Area

Table F-3. Peak Wet Weather Flow at Pump Stations.

Table F-4. Recommended Collection System Improvement Projects

Table F-5. Summary of Capital Improvement Projects

List of Figures Figure 8-1. Average Dry Weather Flow and Peaking Factors

Figure A-1. Organization Chart of Wastewater Utility Staff

Figure C-1. Lathrop Wastewater Infrastructure

Figure C-2. Lathrop Sewer Collection Service Area

Figure E-1. Location of Food Service Facilities in Lathrop

Figure F-1. Overview of Capital Improvement Projects

Appendices APPENDIX A – Element 2 (Organization) Supporting Documents

APPENDIX B – Element 3 (Legal Authority) Supporting Documents

APPENDIX C – Element 4 (Operations and Maintenance Program) Supporting

Documents

APPENDIX D – Element 6 (Overflow Emergency Response Plan) Supporting

Documents

APPENDIX E – Element 7 (Fats, Oils and Grease (FOG) Control Program) Supporting

Documents

APPENDIX F – Element 8 (System Evaluation and Capacity Assurance Plan) Supporting

Documents

APPENDIX G – Element 9 (Monitoring, Measurement, & Program Modifications)

Supporting Documents

APPENDIX H – Element 10 (SSMP Program Audits) Supporting Documents

APPENDIX I – Element 11 (Communication Program) Supporting Documents

Introduction

City of Lathrop Sewer System Management Plan 1

INTRODUCTION This introductory section provides background information on the purpose and

organization of this City of Lathrop (City) Sewer System Management Plan (SSMP) and

provides a brief overview of the City’s service area and sewer system.

SSMP Requirement Background

This SSMP has been prepared in compliance with the requirements contained in State

Water Resources Control Board (SWRCB) General Order No. 2006-0003-DWQ. This

order was adopted at its meeting on May 2, 2006 to require all public wastewater collection

system agencies in California with greater than one mile of sewers to be regulated under

General Waste Discharge Requirements (GWDR). The SWRCB action also mandates the

development of an SSMP and the reporting of sewer system overflows (SSOs) using an

electronic reporting system. On July 30, 2013, Attachment A to the Order which became

effective on September 9, 2013, amended the Monitoring and Reporting Program (MRP)

to the GWDR. Together these documents constitute the “SSS WDR”.

This SSMP was originally adopted in July 2009 and was updated in 2013, 2016, and 2018.

A history of changes and amendments to the SSMP since the City’s first adoption in 2009

is included in the SSMP Change Log in Appendix G.

Document Organization

This SSMP includes eleven elements, as listed below and required in the SSS WDR. Each

of these elements forms a section of this document.

1. Goals

2. Organization

3. Legal Authority

4. Operation and Maintenance Provisions

5. Design and Performance Provisions

6. Overflow Emergency Response Plan

7. Fats, Oils and Grease Control Program

8. System Evaluation and Capacity Assurance Plan

9. Monitoring, Measurement, and Program Modifications

10. SSMP Program Audits

11. Communication Plan

Introduction


Each element section is organized into sub-sections, as follows:

• Description of the regulatory requirements for that element, included italicized font

in grey text boxes at the beginning to each element;

• Identification of associated appendix and list of supporting information included in

the appendix; and

• Discussion of the element. The discussion may be split into multiple sub-sections

depending on length and complexity.

Supporting information for each element is included in an appendix associated with that

section, as applicable. In general, information expected to require relatively frequent

updates (such as names and phone numbers of staff) are included in appendices, as well as

other supporting information, such as forms or schedules.

City Service Area and Sewer System

The City of Lathrop (City) is located 70 miles east of San Francisco in San Joaquin County.

It is located at the interchange of three major freeways: Interstate 5 (I-5), Interstate 205 (I-

205), and State Route 120 (SR-120). The City of Lathrop is located nearby or adjacent to

unincorporated areas of San Joaquin County and the City of Stockton towards the north,

the City of Manteca towards the east, the City of Tracy towards the south, and the San

Joaquin –Sacramento River Delta towards the west. The City has an area of 21 square miles

of level terrain, and a population of 22,112 in 20161.

The City’s wastewater is conveyed by two separate collection systems to two publicly

owned wastewater treatment plants (POTWs) that are operated under two separate permits

administered by the RWQCB:

1. Collection system “WRP-1 MBR” (Place ID 631511), which conveys wastewater

from the Crossroads industrial area and the areas west of I-5, including the

Mossdale, River Islands, and Central Lathrop areas to the Lathrop Consolidated

Treatment Facility (CTF, formerly known as WRP-1);

2. Collection system “Lathrop CS to MWQCF CS” (Place ID 630812), which conveys

wastewater from areas east of I-5 that are not part of the Crossroads industrial area

to the Manteca Water Quality Control Facility (MWQCF).

Several large industrial facilities (e.g., Simplot, a future Kraft-Heinz facility, Sharpe Army

Depot, and former Carpenter Company facility) as well as the Next Generation STEAM

Academy in River Islands manage their wastewater onsite. California Natural Products

manages the majority of their wastewater and sends the remaining flows to either the J

Street Lift Station (LS) or the McKinley Avenue Pump Station (PS).

1 California DOF 2016. E-4 Population Estimates for Cities, Counties, and the State, 2011-2016

with 2010 Census Benchmark. May 2016.

Introduction


Wastewater generated in the Crossroads industrial area used to be treated at the Crossroads

wastewater treatment facility, which was decommissioned in 2015 and is now combined

with the CTF. The CTF produces tertiary treated recycled water that is stored in recycled

water storage ponds and distributed to designated land application areas.

The City’s wastewater collection systems consist of approximately 72 miles of gravity

mains, 21 miles of force mains, as well as 12 lift and pump stations. The City has a

supervisory control and data acquisition (SCADA) system for control and monitoring of

facilities.

Element 1: Goals


ELEMENT 1: GOALS The summarized requirements for the Goals element of the SSMP are as follows:

1.1 Regulatory Requirements for Goals Element

1.2 Element 1 Appendix

None

1.3 Goals Discussion

In support of this SSMP, the City has developed the following goals to properly manage,

operate and maintain its sewer system:

1. To properly manage, operate, and maintain all portions of the City’s sewer system.

2. To prevent public health hazards.

3. To meet all applicable regulatory notification, monitoring, and reporting

requirements.

4. Use funds available for sewer operations in the most efficient manner by

performing preventative maintenance and extending the useful life of the sewer

system.

5. Convey wastewater to treatment facilities with a minimum of infiltration, inflow,

and exfiltration.

6. Provide adequate capacity to convey peak wastewater flows.

This SSMP will contribute to the proper management of the collection system and assist

the City in preventing public health hazards due to SSOs by providing guidance for

appropriate maintenance, capacity management, and emergency response.

D.13.(i) Goals: The goal of the SSMP is to provide a plan and schedule to properly manage,

operate, and maintain all parts of the sanitary sewer system. This will help reduce and prevent

SSOs, as well as mitigate any SSOs that do occur.

Element 2: Organization


ELEMENT 2: ORGANIZATION This section of the SSMP identifies City staff who are responsible for implementing this

SSMP, responding to SSO events, and meeting the SSO reporting requirements. This

section also includes the designation of the Authorized Representative to meet SWRCB

requirements for completing and certifying spill reports.

2.1 Regulatory Requirements for Organization Element

2.2 Element 2 Appendix A

Supporting information for Element 2 is included in Appendix A. This appendix includes

the following documents:

1. Figure A-1. Organization Chart of Wastewater Utility Staff

2. Description of General Responsibilities for Wastewater Utility Staff

3. Table A-1. Names and Telephone Numbers of Staff Responsible for SSMP

4. Table A-2. List of Staff Responsible for SSMP Elements

2.3 Organization Discussion

This section discusses the organization and roles of wastewater utility staff, the authorized

representative to the SWRCB, and key staff responsible for implementing and maintaining

the SSMP.

Department Organization

The organization chart for the management, operation, and maintenance of the City’s

wastewater collection system is shown on Appendix A, Figure A-1. The names and phone

numbers of staff filling these positions are included in Appendix A, Table A-1.

D.13.(ii) Organization: The SSMP must identify:

a) The name of the responsible or authorized representative as described in Section J of

this Order (SSS WDR).

b) The names and telephone numbers for management, administrative, and maintenance

positions responsible for implementing specific measures in the SSMP program. The

SSMP must identify lines of authority through an organization chart or similar

document with a narrative explanation; and

c) The chain of communication for reporting SSOs, from receipt of a complaint or other

information, including the person responsible for reporting SSOs to the State and

Regional Water Board and other agencies if applicable (such as County Health Officer,

County Environmental Health Agency, Regional Water Board, and/or State Office of

Emergency Services (Cal OES)).



Description of General Responsibilities

Descriptions of Public Works Department (PWD) staff responsibilities are included in

Appendix A.

The PWD Operations and Maintenance (O&M) Division have the lead responsibility for

the operation and maintenance of the collection system. PWD O&M staff have the primary

responsibility to respond to, clean up, and document SSOs from the collection system,

including from lift and pump stations. PWD Administrative staff have primary

responsibility to log all documentation of any SSOs and assist the City’s authorized

representatives in providing any necessary agency notifications. Contract operators (i.e.,

Veolia Water, North America [VWNA]) at CTF are responsible for monitoring quality and

quantity of water generated and received at the plant.

The PWD Engineering Division have the primary responsibility in planning, design, and

construction of the collection system’s Capital Improvement Projects (CIPs). The Senior

Construction Inspector is responsible for ensuring the new and rehabilitated assets meets

the City’s standards.

Authorized Representative

The City’s authorized representative in all wastewater collection system matters is the

Public Works Director or his designee. The Public Works Director or his designee is

authorized to certify electronic spill reports submitted to the RWQCB via the California

Integrated Water Quality System (CIWQS) and is a legally responsible official (LRO).

The City Manager and Senior Civil Engineers have been designated as “Onsite Managers”

and are LROs who can certify electronic SSO reports in CIWQS. Multiple LROs ensure

the City has continuous LRO coverage.

The O&M Superintendent is authorized to submit SSO reports to the appropriate

government agencies and is designated as a Data Submitter in the CIWQS system.

Responsibility for SSMP Implementation

Description of general responsibilities for City staff for implementing specific measures in

the SSMP program are provided in Appendix A, Table A-2.

2.4 SSO Reporting Chain of Communication

The chain of communication for reporting SSOs is included in the City’s Overflow

Emergency Response Plan (OERP) in Appendix D. The O&M Superintendent has the lead

responsibility for reporting SSOs to the appropriate regulatory agencies, with the assistance

from PWD O&M staff and Administrative staff.

Officials receiving immediate notification of the SSO vary depending on the size of the

spill and whether or not the spill contains hazardous materials, affects surface waters, or

has the potential to impact human health. Table 2-1 lists these officials and the

circumstances under which they are notified immediately. Detailed notification procedures

are described in Section VII of the OERP.



TABLE 2-1

OFFICIALS RECEIVING IMMEDIATE NOTIFICATION OF SSO

Contact Circumstance for Immediate Notification

PWD O&M Superintendent All SSOs.

PWD Maintenance Supervisor All SSOs.

Public Works Director Major SSOs (greater than 1,000 gallons), or

those affecting surface water or human health.

City Manager Major SSOs (greater than 50,000 gallons), or


California Office of Emergency

Services (within 2 hours)

Major SSOs (greater than 1,000 gallons)

affecting or could potentially affect surface

water or human health.

Regional Water Quality Control Board

(within 72 hours)

Major SSOs (greater than 1,000 gallons), or


(SSO Categories 1 and 2)

Lathrop Manteca Fire Department SSOs involving hazardous materials.

San Joaquin County Department of

Environmental Health

SSOs that may impact human health.

State Water Resources Control Board,

Division of Drinking Water

SSOs affecting the City’s Drinking Water

System or water supplies.

California Department of Fish and

Wildlife

SSOs causing a fish kill.

South San Joaquin Irrigation District SSOs resulting in a discharge into the South

San Joaquin Irrigation District Canal.

Element 3: Legal Authority


ELEMENT 3: LEGAL AUTHORITY This element of the SSMP discusses the City’s Legal Authority, including its Municipal

Code and agreements with other agencies. This section fulfills the Legal Authority

requirement of the SWRCB (Element 3)

3.1 Regulatory Requirements for Legal Authority Element

The requirements for the Legal Authority element of the SSMP (Element 3) are

summarized below:

3.2 Element 3 Appendix B

Supporting information for Element 3 is included in Appendix B. This appendix includes


1. Enforcement Response Plan – Enforcement of Sewer Use Ordinance

2. Enforcement Response Plan – Fats, Oils & Grease Source Control Program

3. Interjurisdictional Agreement Between the City of Manteca and The City of

Lathrop.

3.3 Municipal Code

The legal authority required for the SSMP by the SWRCB is contained within the City’s

municipal code. Two chapters of the municipal code are dedicated to the sewer system, all

included in Lathrop Municipal Code (LMC) Title 13, Public Services:

1. LMC Chapter 13.16 – Sewer Service System

2. LMC Chapter 13.26 – Sewer Use and Industrial Wastewater Regulations

Chapters 13.16 and 13.26, as listed above, pertain to the legal authority required for

fulfillment of SSMP requirements. These chapters are available on the City’s website at

http://www.ci.lathrop.ca.us/lathrop/cco/municodes.aspx. Portions of these chapters are

D.13.(iii) Legal Authority: Each Enrollee must demonstrate, through sanitary sewer system

use ordinances, service agreements, or other legally binding procedures, that it possesses the

necessary legal authority to:

a) Prevent illicit discharges into its sanitary sewer system (examples may include

infiltration and inflow (I/I), storm water, chemical dumping, unauthorized debris and

cut roots, etc…);

b) Require that sewers and connections be properly designed and constructed;

c) Ensure access for maintenance, inspection, or repairs for portions of the lateral owned

or maintained by the Public Agency;

d) Limit the discharge of fats, oils, and grease and other debris that may cause blockages,

and

(e) Enforce any violation of its sewer ordinances.

http://www.ci.lathrop.ca.us/lathrop/cco/municodes.aspx



discussed in the following sub-sections as they pertain to prevention of illicit discharges,

proper design and construction of sewer and connections, maintenance access, and

enforcement measures. Additional code sections providing legal authority that is

referenced but not required by the SWRCB are listed in Table B-1 of Appendix B.

Prevention of Illicit Discharges

Measures prohibiting illicit discharges to the sewer system are included in the following

sections of LMC Chapter 13.16:

• Section 13.16.050 describes the prohibition of discharging storm water to the sewer

system;

• Section 13.16.060 describes the prohibitions of excessive use of sewers; and

• Section 13.16.070 specifically demonstrates the City’s legal authority for

preventing illicit discharges of substances containing chemicals and unauthorized

debris which may interfere with the operation of the sewer system.

Proper Design and Construction of Sewers and Connections

LMC Sections 13.16.100 and 13.16.110 requires approval of plans and specifications for

sewerage construction prior to construction. If a facility will generate and discharge

industrial wastewater, a permit for industrial wastewater discharge must be obtained. In

accordance with Section 13.16.110, the City requires that all new design and construction

of sewers and connections meet the City of Lathrop PWD Design and Construction

Standards, as discussed in Element 5.

The City has adopted the 2016 California Plumbing Code by reference in LMC Section

15.12.010. The plumbing code requires the proper construction of privately owned sewer

lines.

Lateral Maintenance Access

LMC Section 13.16.150 states the property owner is responsible for maintenance,

inspection, and repairs of the lateral on private property (from the building to the cleanout

located at the public right of way or easement line). Laterals maintained by the City exist

within the public right of way or are located within a public utility easement. LMC Section

13.16.280 requires access to all facilities directly or indirectly connected to the City sewer

system to be given to authorized personnel of the City at all reasonable times, including

during emergencies.

Limit Discharge of FOG and Other Debris

LMC Section 13.16.070 prohibits the discharge of any water or waste containing floatable

or dispersed grease (defined as an oil, fat, and grease, or other ether soluble matter) in

excess of 50 milligrams per liter (mg/L). The section also restricts the discharge of other

types of debris.

Enforcement Measures

LMC 13.16 and 13.26 provide penalties for violation of any of the provisions of its chapter.

Per LMC 13.26.100, the City has adopted Enforcement Response Plans for the City’s



Industrial Pretreatment Program and FOG Control Program. The Enforcement Response

Plans are included in Appendix B.

3.4 Agreements with Other Agencies

City of Manteca Interjurisdictional Sewer Agreement

The City of Lathrop has an agreement with the City of Manteca that allows Lathrop to

utilize up to 14.7% of the wastewater treatment capacity of the MWQCF. In accordance

with a request from the RWQCB, the City of Lathrop has adopted an interjurisdictional

agreement and adopted an industrial pretreatment program, sewer ordinance, and local

limits that are at least as stringent as the City of Manteca’s. The interjurisdictional

agreement is included in Appendix B and designates Manteca as the agent of Lathrop for

implementation and enforcement of Lathrop’s sewer ordinance against industrial

dischargers to the MWQCF system located in Lathrop. Manteca issues permits to all

industrial dischargers to the MWQCF system, and conducts inspections, sampling and

analysis, and other duties required by Federal and State law or National Pollutant Discharge

Elimination System (NPDES) permit.

Element 4: Operations and Maintenance Program


ELEMENT 4: OPERATIONS AND MAINTENANCE PROGRAM This section of the SSMP discusses the City’s operations, maintenance and other related

measures and activities. This section fulfills the Operation and Maintenance Program

SSMP requirement for the SWRCB (Element 4).

4.1 Regulatory Requirements for Operations and Maintenance Program

4.2 Element 4 Appendix C

Supporting information for Element 4 is included in Appendix C. This appendix includes


1. Figure C-1. City of Lathrop Wastewater Infrastructure

2. Figure C-2. City of Lathrop Sewer Collection Systems and Pump Station

Drainage Areas

3. Sewer Flushing Report Form

D.13.(iv) Operation and Maintenance Program: The SSMP must include those elements listed

below that are appropriate and applicable to the Enrollee’s system:

a) Maintain an up-to-date map of the sanitary sewer system, showing all gravity line

segments and manholes, pumping facilities, pressure pipes and valves, and applicable

storm water conveyance facilities;

b) Describe routine preventive operation and maintenance activities by staff and

contractors; including a system for scheduling regular maintenance and cleaning of

the sanitary sewer system with more frequent cleaning and maintenance targeted at

known problem areas. The Preventative Maintenance (PM) program should have a

system to document scheduled and conducted activities, such as work orders;

c) Develop rehabilitation and replacement plan to identify and prioritize system

deficiencies and implement short-term and long-term rehabilitation actions to address

each deficiency. The program should include regular visual and TV inspections of

manholes and sewer pipes, and a system for ranking the condition of sewer pipes and

scheduling rehabilitation. Rehabilitation and replacement should focus on sewer pipes

that are at risk of collapse or prone to more frequent blockages due to pipe defects.

Finally, the rehabilitation and replacement plan should include a capital improvement

plan that addresses proper management and protection of the infrastructure assets.

The plan shall include a time schedule for implementing the short and long term plans

plus a schedule for developing the funds needed for the capital improvement plan;

d) Provide training on a regular basis for staff in sanitary sewer system operations,

maintenance, and require contractors to be appropriately trained; and

e) Provide equipment and replacement part inventories, including identification of

critical replacement parts.



4. Daily Lift Station Inspections Report Form

5. Pump Inspection Report Form

6. Force Main Inspection Report

7. Air/Vacuum Release Valve Report

8. Table C-1. Wastewater Pump Station Pump and Motor Information

4.3 Collection System Map Discussion

The City has developed and maintains a geographical information system (GIS) database

and maps of its wastewater collection system. The majority of the existing wastewater

collection system has been mapped and data collection for asset management is ongoing.

Maps of the wastewater infrastructure and service areas and collection systems are shown

in Appendix C. These figures illustrate locations of lift stations, pump stations, sewer

manholes, and sewer lines.

The City’s GIS database of the wastewater collection system contains data including pipe

upstream and downstream manholes and invert elevations, diameter, material, length,

slope, install date, as-built or plan source, and comments. The City regularly updates the

GIS database to fix errors and add new infrastructure from as-built records.

The information maintained in GIS are printed onto a map book of 11”x17” maps for use

by O&M and Engineering staff. The City also maintains copies of the original

improvement plans or as-built drawings for reference.

4.4 O&M Activities

To ensure proper operation of the collection system, PWD O&M staff and contract

treatment operators perform routine preventative operation and maintenance activities.

This includes checking the SCADA system panel daily to monitor system performance,

perform routine searches, record meter readings, and create performance charts. It also

includes system inspections performed at the frequency described in Table 4-1.



TABLE 4-1

ROUTINE INSPECTION OF KEY COLLECTION SYSTEM COMPONENTS

System Components Inspection Routine Lead Responsibility

Monitor lift stations for general operation Daily O&M staff

Detailed inspection of lift stations Twice per year O&M staff

Monitor Crossroads lift station for general

operation

Daily CTF operators

Detailed inspection of Crossroads lift

station

Once per year CTF operators

Inspect and flush sewer and manholes Complete cycle every

five years

O&M staff

Inspect ARVs condition Once per week O&M staff

Inspect force mains to CTF Once per week O&M staff

Inspect force mains to MWQCF Once per week O&M staff

The PWD uses an asset management software (SEMS system) to manage its asset

inventory, schedule maintenance, and manage work orders. The SEMS system stores a

library of asset characteristics including name, location, manuals, images, depreciation,

maintenance schedule, and work order history. Maintenance work orders are automatically

created for each asset based on the routine inspection schedule shown above. The software

can also manage system repairs and customer service orders created by staff members.

Sewer Cleaning and Manhole Inspection

Sewer lines are cleaned and flushed on a five-year cycle goal (20 percent of the collection

system per year). In addition, the City identifies problem areas that need to be cleaned more

frequently, and cleans these areas every two to three months.

With the flushing of each sewer line, each upstream and downstream manhole is inspected.

For each upstream and downstream manhole inspected and flushed, the following

information is recorded: date, operator names, location of the originating and receiving

manholes, line size, line material, line length, number of runs to clear line, condition of

line, depth to invert(s), number of drops in manhole, number of influent and effluent mains

in manhole, number of laterals in manhole, and direction of flushing. All observations are

recorded on the “Wastewater Hydroflushing Log” contained in Appendix C.

Lift Station Inspection

On a daily basis, crews monitor the SCADA system electronically for lift stations alarms

and general troubleshooting. Pump run times are recorded to determine if pumps are

operating properly. Data are noted on the “Lift Station Inspections Report” form contained

in Appendix C.

Twice per year, all lift station pumps are lifted from the wet well and inspected. The

condition of each of the following components is noted: oil level, oil condition, wear rings,

case, volute, pull cable, cord seal, noise, vibration, level sensor, floats, panel, warning



lights, and amperage draw. All observations are recorded on the “Pump Inspection Report”

form contained in Appendix C.

Air/Vacuum Release Valves (ARVs) Condition

Once per week, ARVs on force mains are inspected. The following items are inspected on

the ARVs:

1. Two inch ball valve is exercised and checked

2. ARV manhole is checked for evidence of SSOs

3. Air release is inspected

4. Vacuum break is inspected

All observations are recorded on the “Air/Vacuum Release Valve Report” form contained

in Appendix C.

Force Mains to CTF and MWQCF

Once per week, the force mains to the MWQCF and the CTF are driven and inspected. The

manholes are opened and the force main is inspected. All observations are noted on the

“Force Main Inspection Report” form contained in Appendix C.

Pipeline Inspection

The PWD owns equipment and routinely performs closed circuit television (CCTV)

inspections of the City’s sewer pipelines. The PWD goal is to incorporate a procedure for

conducting CCTV inspections on 10 percent of the collection system each year, resulting

in a complete inspection over a ten-year period. Priority will be given to those lines that

have had historical problems or have recently backed up. Results of the CCTV inspections

would be used to determine low, medium, and high areas of concern within the collection

system, increase cleaning efforts and develop a capital improvement program to correct the

areas of concern where practical.

Investigation of Customer Complaints

The City responds to customer complaints about sewer service, which are generally related

to sewer stoppages, SSOs, or odors. Response is performed by the PWD staff during work

hours2 and the on-call operator during afterhours. After receiving a customer compliant,

the responder records the complaint on the SEMS system, assess the complaint, and resolve

the issue. The City’s initial response time goal is 30 minutes.

The majority of the complaints are related to stoppages and most of the stoppages occur in

laterals. Although the City responds to all stoppage complaints, it is not responsible for

clearing stoppages in laterals located on private property or outside of the public right-of-

way.

2 8:00AM - 6:00PM Monday – Thursday; 8:00AM - 5:00 PM Friday.



4.5 Rehabilitation and Replacement Plan

The City has three methods of scheduling and funding rehabilitation and replacement of

existing capital and equipment within the collection system:

1. Routine maintenance is budgeted annually and is planned by O&M staff as

scheduled and/or needed;

2. Scheduling and funding for capital and equipment replacement is also through the

departmental budget - scheduled and emergency repairs are funded under this item

when the costs of the equipment can be deemed an investment in the system, usually

over $1,000; and

3. The capital improvement program can be used for replacement and new

construction - this method of scheduling and budgeting is used for very large

replacement projects or when expansion or oversizing of the facility is needed. The

City’s five-year Capital Improvement Program identifies the implementation

schedule and funding sources for collection system CIPs and is available on the

City’s website at http://www.ci.lathrop.ca.us/pwd/cip.aspx.

Capital and equipment replacement reflects inspection reports recorded during routine

maintenance, input from PWD staff, and results of consultant/contractor evaluations of the

collection system as described in Section 4.4. Records of equipment inventory and

inspection are maintained in the PWD and the SEMS asset management software that helps

manage utility information and improve wastewater planning and services.

The PWD has several goals to improve the current rehabilitation and replacement plan.

These goals include:

1. Develop a list which projects the timeframe for equipment and parts replacement

needs. The list will be vital for developing a schedule for implementing short and

long-term needs and coordinating funding for those needs. Check time frame

estimates annually with equipment operation logs for run time and inspection

reports.

2. Develop a formal method for using available operation and maintenance data such

as inspection reports, historical SSOs, and field observations to rank the condition

of parts of the collection system. Use the results of the ranking for scheduling

rehabilitation activities.

3. Upgrade the City’s Asset Management program and Computerized Maintenance

Management System (CMMS) technologies to tie to the City’s GIS database.

4.6 Training

PWD O&M staff are trained on a regular basis on use of the sewer cleaning equipment,

methods for flushing the sewer system, work safety, permitting requirements and

emergency response procedures. General tailgate safety meetings are held each Tuesday

for operators. Updates regarding the sewer system are generally announced at these

meetings.

http://www.ci.lathrop.ca.us/pwd/cip.aspx



PWD O&M staff also attend pump inspection classes and sewer-jetting truck (Vac-Con)

equipment training. All PWD O&M staff are required obtain the Collection System

Maintenance certificate from the California Water Environment Association and complete

the operator training program at Sacramento State University.

4.7 Equipment and Replacement Parts

Operation and maintenance manuals for most of the pump stations and equipment are

available. The operation and maintenance manuals contain manufacturer information

pertaining to recommended maintenance procedures and parts lists. A small inventory of

spare parts such as washers, packing, and lanyards are maintained by the PWD. Larger

parts such as impellers and motors for pumps are ordered as needed. Because the pump

stations are designed with one redundant pumping unit, sufficient time is typically available

for ordering replacement parts and repairing the units. Information on the pumps at the

existing City pump and lift stations is provided in Appendix C. The City also maintains a

contract with an outside company for providing back-up sewer cleaner trucks when needed.

Element 5: Design & Performance Provisions


ELEMENT 5: DESIGN & PERFORMANCE PROVISIONS This section of the SSMP discusses the City’s design and construction standards. This

section fulfills the Design and Performance Provisions SSMP requirement for the SWRCB

(Element 5).

5.1 Regulatory Requirements for Design & Performance Provisions

5.2 Element 5 Appendix

None.

5.3 Design & Performance Provisions Discussion

The PWD Design and Construction Standards (“Standards”) are available at the City’s

website (http://www.ci.lathrop.ca.us/pwd/standards/Default.aspx) and includes standards

and specifications for the sewer collection system, pump stations, and other appurtenances

and for the rehabilitation and repair of existing sanitary sewer systems.

The City typically updates its Standards every five years, or as needed. The most recent

update of the Design and Construction Standards was in January 2014. The City’s

wastewater generation factors and capacity design criteria were updated as part of its 2018

Master Plan update and will be incorporated in the Standards.

The City Standards also include testing and inspection procedures for sewer projects. The

PWD has a full-time construction inspector for public works projects, who is responsible

for inspection and testing of the installation of new sewers, pumps, and other appurtenances

and for rehabilitation and repair projects.

D.13.(v) Design and Performance Provisions:

a) Design and construction standards and specifications for the installation of new

sanitary sewer systems, pump stations and other appurtenances; and for the

rehabilitation and repair of existing sanitary sewer systems; and

b) Procedures and standards for inspecting and testing the installation of new sewers,

pumps, and other appurtenances and for rehabilitation and repair projects.

http://www.ci.lathrop.ca.us/pwd/standards/Default.aspx

Element 6: Overflow Emergency Response Plan


ELEMENT 6: OVERFLOW EMERGENCY RESPONSE PLAN The section of the SSMP provides an overview and summary of the City’s emergency

response documents and procedures for SSOs. This section fulfills the Overflow

Emergency Response Plan requirement of the SWRCB (Element 6) SSMP requirements. Complete documentation of SSO response procedures are attached in Appendix D.

6.1 Regulatory Requirements for Overflow Emergency Response Plan Element

6.2 Element 6 Appendix D

Supporting information for Element 6 is included in Appendix D. This appendix includes



2. Overflow Emergency Response Plan SSO Reporting Chain of Communication

3. Overflow Emergency Response Plan List of Contacts

D.13.(vi) Overflow Emergency Response Plan - Each Enrollee shall develop and implement

an overflow emergency response plan that identifies measures to protect public health and the

environment. At a minimum, this plan must include the following:

a) Proper notification procedures so that the primary responders and regulatory agencies

are informed of all SSOs in a timely manner;

b) A program to ensure appropriate response to all overflows;

c) Procedures to ensure prompt notification to appropriate regulatory agencies and other

potentially affected entities (e.g. health agencies, regional water boards, water

suppliers, etc…) of all SSOs that potentially affect public health or reach the waters of

the State in accordance with the MRP. All SSOs shall be reported in accordance with

this MRP, the California Water Code, other State Law, and other applicable Regional

Water Board WDR or NPDES permit requirements. The SSMP should identify the

officials who will receive immediate notification;

d) Procedures to ensure that appropriate staff and contractor personnel are aware of and

follow the Emergency Response Plan and are appropriately trained;

e) Procedures to address emergency operations, such as traffic and crowd control and

other necessary response activities; and

f) A program to ensure that all reasonable steps are taken to contain and prevent the

discharge of untreated and partially treated wastewater to waters of the United States

and to minimize or correct any adverse impact on the environment resulting from the

SSOs, including such accelerated or additional monitoring as may be necessary to

determine the nature and impact of the discharge.



4. Procedures for Estimating the Volume of Sewer Overflows

5. Sanitary Sewer Overflow Report Form

6.3 Overflow Emergency Response Plan

The City’s Overflow Emergency Response Plan (OERP) is organized into nine sections, as

follows:

I. Overflow Detection

II. Initial Response

III. Recovery and Clean-up (Mitigation)

IV. Public Access and Warning

V. Water Quality Sampling and Analysis

VI. Investigation and Documentation

VII. Regulatory Notification and Reporting

VIII. Equipment

IX. Training

Objectives of the City’s OERP are to protect public health and the environment, satisfy

regulatory agency requirements, and minimize risk of enforcement actions against the City.

Additional objectives include providing appropriate customer service and protecting City

personnel, the collection system and facilities, and private and public property.

The City’s OERP, included as part of this SSMP, is also maintained in a separate binder

and kept at the PWD for use by O&M staff. This allows staff to easily reference the OERP

without having to carry complete copy of the SSMP.

Overflow Detection

This section of the plan details procedures for SSO detection, either by the public, City

employees, or through the City’s SCADA system. This section includes procedures for the

PWD receptionist or on-call employee to receive and record relevant information regarding a

possible SSO from a caller.

Initial Response

This section details procedures when the maintenance crew first arrives at the site of a SSO. It

is the responsibility of the first personnel to arrive at the site of a SSO to protect the health and

safety of the public by mitigating the impact of the SSO to the maximum extent possible. Upon

arrival, the crew is responsible for determining the cause of the SSO, assessing the need for

additional equipment or assistance, notifying the dispatcher to contact appropriate agencies if

immediate notification is needed, and taking immediate steps to stop the SSO. Guidelines for

completing and documenting a preliminary damage assessment are provided, and coordination

with any hazardous material response is explained.

Recovery and Clean-up (Mitigation)

This section describes recovery and clean-up procedures to be performed by the sewer

maintenance crew to restore the site to normal. Specific clean-up procedures are provided for

paved areas, areas with bare soil or vegetation, and environmentally sensitive areas.



Public Access and Warning

This section describes procedures to set up barricades and post warning signs where public

health may be at risk by contract with sewage or sewage contamination.

Water Quality Sampling and Analysis

This section describes how water quality samples shall be taken in any body of water

receiving sewage to determine the extent of the contamination. Water quality sampling

should be performed to:

1. Determine the extent of the area that has been impacted by sewage contamination;

and

2. Determine when the area is safe for public contact.

Water quality samples may be taken by trained staff or an independent water quality testing

laboratory under contract with the City.

Investigation and Documentation

Procedures for investigation and documentation of SSOs are provided in this section of the

OERP. Information obtained for the SSO shall be recorded on the Internal Sanitary Sewer

Overflow Report Form provided in Appendix D. All information and documentation shall

be kept in a file created for each SSO event. A checklist of the information that should be

included to document the SSO event is provided in Appendix D.

Regulatory Notification and Reporting

Procedures for notification and reporting are provided in this section of the OERP for each

of the three SSO categories established by the SWRCB:

1. Category 1: Discharges of untreated or partially treated wastewater of any volume

resulting from an enrollee’s sanitary sewer system failure or flow conditions that:

a. Reach surface water and/or reach a drainage channel tributary to a surface

water; or

b. Reach a municipal separate storm sewer system (MS4) and are not fully

captured and returned to the sanitary sewer system or not otherwise captured

and disposed of properly. Any volume of wastewater not recovered from

the MS4 is considered to have reached surface water unless the storm drain

system discharges to a dedicated storm water or groundwater infiltration

basin (e.g., infiltration pit, percolation pond).

2. Category 2: Discharges of untreated or partially treated wastewater greater than or

equal to 1,000 gallons resulting from an enrollee’s sanitary sewer system failure or

flow condition that does not reach a surface water, a drainage channel, or the MS4

unless the entire SSO volume discharged to the storm drain system is fully

recovered and disposed of properly.



3. Category 3: All other discharges of untreated or partially treated wastewater

resulting from an enrollee’s sanitary sewer system failure or flow condition.

4. Private Lateral Sewage Discharges: Discharges of untreated or partially treated

wastewater resulting from blockages or other problems within a privately-owned

sewer lateral connected to the City’s sanitary sewer system or other private sewer

assets.

The OERP lists the information that needs to be reported to the California Office of

Emergency Services (Cal OES), the Central Valley RWQCB, and the CIWQS online

database. Procedures for notification of San Joaquin Department of Environmental Health,

California Department of Fish and Wildlife, South San Joaquin Irrigation District, and local

agencies and officials are also provided in the plan. A summary of regulatory agencies to

be notified immediately of an SSO is provide in Table 2-1.

Equipment

This section of the OERP provides a list and description of equipment required to respond

to a SSO such as:

• Vac-Con Truck

• Portable Pumps and Hoses

• Street Sweeper

• CCTV Inspection Unit

• Emergency Response Truck(s)/Trailer

• Photographic Equipment

• GPS Unit

Training

This section of the OERP provides training procedures for personnel that may have a role

in responding to a SSO. Initial and annual refresher training in SSO response will be

provided to all employees to ensure they are appropriately trained. SSO response exercises

will be held to ensure that employees are up to date on the procedures, to verify the

equipment is in working order, and the required materials are readily available. The training

exercises should cover scenarios typically observed during sewer-related emergencies (e.g.

mainline blockage, mainline failure, force main failure, pump station failure, and lateral

blockage). Records shall be kept of all training that is provided in support of this plan.

Element 7: Fats, Oils and Grease (FOG) Control Program


ELEMENT 7: FATS, OILS, AND GREASE (FOG) CONTROL PROGRAM This section of the SSMP discusses the City’s FOG control measures, including

identification of problem areas, focused cleaning, and source control. This section fulfills

the FOG Control requirement for the SWRCB (Element 7) SSMP requirements.

7.1 Regulatory Requirements for FOG Control Element

7.2 Element 7 Appendix E

Supporting information for Element 7 is included in Appendix E. This appendix includes


1. Table E-1. List of Food Service Facilities in Lathrop

2. Figure E-1. Location of Food Service Facilities in Lathrop

3. City of Lathrop - Industrial Pretreatment Program, Implementation Procedures.

4. “Preventing Sewer Backups” public outreach brochure.

D.13.(vii) Fats, Oils, and Grease (FOG) Control Program: Each Enrollee shall evaluate its

service area to determine whether a FOG control program is needed. If an Enrollee determines

that a FOG program is not needed, the Enrollee must provide justification for why it is not

needed. If FOG is found to be a problem, the Enrollee must prepare and implement a FOG

source control program to reduce the amount of these substances discharged to the sanitary

sewer system. This plan shall include the following as appropriate:

a) An implementation plan and schedule for a public education outreach program that

promotes proper disposal of FOG;

b) A plan and schedule for the disposal of FOG generated within the sanitary sewer

system service area. This may include a list of acceptable disposal facilities and/or

additional facilities needed to adequately dispose of FOG generated within a sanitary

sewer system service area;

c) The legal authority to prohibit discharges to the system and identify measures to

prevent SSOs and blockages caused by FOG;

d) Requirements to install grease removal devices (such as traps or interceptors) design

standards for the removal devices, maintenance requirements, BMP requirements,

record keeping and reporting requirements;

e) Authority to inspect grease producing facilities, enforcement authorities, and whether

the Enrollee has sufficient staff to inspect and enforce the FOG ordinance;

f) An identification of sanitary sewer system sections subject to FOG blockages and

establish a cleaning maintenance schedule for each section; and

g) Development and implementation of source control measures, for all sources of FOG

discharged to the sanitary sewer system, for each section identified in (f) above.



7.3 FOG Control Discussion

The City has determined that a FOG control program is necessary per SSMP requirements.

Approximately 47 Food Service Facilities (FSEs) are located within City limits by January

2018 and discharge to City sewers. A list of FSEs in Lathrop identified as potential grease

dischargers is provided in Appendix E; locations of these FSEs are shown on Figure E-1. O&M

staff have also noted the tendency for grease buildup in specific sewer lines and developed

targeted cleaning of these areas. This section discusses measures the City takes to control FOG.

The City’s FOG control program consists of routine sewer cleaning and maintenance as well

as source control. The City has a contract with VWNA to develop and administer the City’s

Industrial Pretreatment Program (IPP) which includes source control for FOG. Implementation

procedures for the FOG program are provided under IMP 16 – Fats, Oils, and Grease Control,

included in Appendix E. The City does not have a FOG disposal plan. However, FSEs within

the City are required to use acceptable disposal facilities (per LMC Section 13.26.160.F) and

maintain grease trap pumping manifests for City inspection.

The following subsections discuss identification and cleaning of grease-prone areas, legal

authority to prohibit grease discharge or require a grease removal device, facility inspection,

and public outreach.

Identification and Sewer Cleaning

The core means of FOG control utilized by the City is (a) identification of trouble spots or

sewer lines that are likely prone to grease accumulation, (b) targeted cleaning of these areas

on a quarterly basis, and (c) inspection of sewers following blockages. Each of these FOG

control measures are discussed in more detail below:

a. Identification of Grease Problem Areas. The City identifies potential grease

problem areas by tracking locations and causes of dry weather blockages

and SSOs. Additionally, debris type and severity are noted by maintenance

crews during routine cleaning. Areas with several restaurants or grease-

producing facilities are also considered likely potential grease problem

areas.

b. Sewer Cleaning. City sewer maintenance crews clean the entire wastewater

collection system at least once every five years. Additional cleaning is

provided on an as-needed basis for areas with a history of stoppages or

overflows on a line, as well as areas expected to be prone to grease buildup

c. Blockage Investigation. The City inspects each sewer following a blockage.

If the source of the grease in a lateral can be identified, the City contacts

that restaurant or source of grease.

Additional information about cleaning and maintenance is included in Element 4 -

Operations and Maintenance Program.



Legal Authority

The LMC establishes legal authority to prohibit discharge of water or waste to the system

containing floatable grease in excess of 50 mg/l or dispersed in excess of fifty (50) mg/l).

The LMC requires grease, oil, or sand interceptors to be provided when, in the opinion of

the Public Works Director, they are necessary for the proper handling of liquid wastes

containing grease in excessive amounts. The interceptors are to be of a type and capacity

approved by the Public Works Director, and shall be located as to be readily and easily

accessible by PWD staff for inspection and cleaning. The grease, oil and sand interceptors

are to be maintained in continuously efficient operation. (LMC Section 13.16.070).

The sewer ordinance and other documents related to the City’s FOG control program are

contained in Appendix B: Enforcement Response Plan – Fat Oil & Grease Source Control

Program (FOG ERP), which is currently administered by VWNA as part of an overall

Industrial Pretreatment Program for the City’s sewer system.

Facility Inspection

Facilities are routinely inspected as part of Lathrop’s FOG control program, typically on a

semi-annual schedule. The City’s Pretreatment Program Coordinator (VWNA) conducts

FOG inspections of the FSEs within the City service area. Facilities are inspected as follow-

up to user surveys to identify new and/or existing sources, for permit termination and

closure, for industrial user monitoring, and for installation and routine inspections of FOG

interceptors and traps. Information on facility inspection procedures is included in the

City’s IPP (Appendix E) and the FOG ERP (Appendix B). A sample Facility Inspection

Form and inspection checklist used during facility inspections is provided in the FOG ERP.

During FOG inspections and enforcement, information regarding the FOG control program

ordinance and kitchen best management practices are provided to FSEs. Sample brochures

are included in the FOG ERP in Appendix B.

Public Outreach

Information on the City’s FOG Control Program is available on the City’s website

(http://www.ci.lathrop.org).

The City produces a brochure entitled “Preventing Sewer Backups and Overflows”, which

targets residential users and discusses how FOG can cause sewer blockages. The brochure also

directs residents to on how to properly dispose of FOG. This brochure is displayed at City Hall

and provided by O&M staff to residents who are affected by a blockage or backup. A copy of

the brochure is included in Appendix E.

http://www.ci.lathrop.org/

Element 8: System Evaluation and Capacity Assurance Plan


ELEMENT 8: SYSTEM EVALUATION AND CAPACITY ASSURANCE PLAN This section of the SSMP discusses City capacity management measures, including the

most recent Master Plan and recommended capacity improvement projects. This section

fulfills the System Evaluation and Capacity Assurance Plan SSMP requirement for the

SWRCB (Element 8).

8.1 Regulatory Requirements for Capacity Management

8.2 Element 8 Appendix F

1. Table F-1. Existing Wastewater Flow by Development Area

2. Table F-2. Projected Wastewater Flow by Development Area

3. Table F-3. Peak Wet Weather Flow at Pump Stations.

4. Table F-4. Recommended Collection System Improvement Projects

5. Table F-5. Summary of Capital Improvement Projects

6. Figure F-1. Overview of Capital Improvement Projects

D.13.(viii) System Evaluation and Capacity Assurance Plan: The Enrollee shall prepare and

implement a capital improvement plan (CIP) that will provide hydraulic capacity of key

sanitary sewer system elements for dry weather peak flow conditions, as well as the appropriate

design storm or wet weather event. At a minimum, the plan must include:

a) Evaluation: Actions needed to evaluate those portions of the sanitary sewer system that

are experiencing or contributing to an SSO discharge caused by hydraulic deficiency.

The evaluation must provide estimates of peak flows (including flows from SSOs that

escape from the system) associated with conditions similar to those causing overflow

events, estimates of the capacity of key system components, hydraulic deficiencies

(including components of the system with limiting capacity) and the major sources that

contribute to the peak flows associated with overflow events;

b) Design Criteria: Where design criteria do not exist or are deficient, undertake the

evaluation identified in “a” above to establish appropriate design criteria; and

c) Capacity Enhancement Measures: The steps needed to establish a short- and long-term

capital improvement plan (CIP) to address identified hydraulic deficiencies including

prioritization, alternatives analysis, and schedules. The CIP may include increases in

pipe size, I/I reduction programs, increases and redundancy in pumping capacity, and

storage facilities. The CIP shall include an implementation schedule and shall identify

sources of funding.

d) Schedule: The Enrollee shall develop a schedule of completion dates for all portions of

the capital improvement program developed in (a-c) above. This schedule shall be

reviewed and updated consistent with the SSMP review and update requirements as

described in Section D. 14.



8.3 Capacity Evaluation

The City evaluates collection system capacity and identifies improvement projects during

its master planning process. The City is currently in the process of updating its Wastewater

System Master Plan (WWSMP) as part of the City’s Integrated Water Resources Master

Plan (IWRMP) Update.

The draft WWSMP’s capacity evaluation assessed the collection system’s ability to carry

existing and projected Peak Wet Weather Flows (PWWFs), which is the highest hourly

flow experienced during the year due to rainfall-induced infiltration and inflow (I&I) and

peak diurnal sanitary flows. A hydraulic model was constructed to assess the ability of the

City’s existing and key planned infrastructure to meet capacity design criteria under

projected PWWF conditions.

The following sections summarize development of wastewater flow unit factors and

wastewater generation projections, the hydraulic assessment of the City’s existing and key

planned infrastructure, and development of recommended wastewater CIPs included in the

2018 Draft WWSMP.

Existing and Future Wastewater Generation

PWWF is calculated by multiplying the Average Dry Weather Flow (ADWF) by a peaking

factor. The established ADWF and the PWWF peaking factor are discussed below.

As part of IWRMP development, land use-specific wastewater generation factors were

established using historic wastewater flow and parcel-level water use data. The wastewater

generation factors serve as the basis to estimate ADWF for future developments. The

IWRMP updated wastewater generation factors (in units of gallons per day per dwelling

unit or gallons per day per acre; gpd/du or gpd/ac) are presented in Table 8-1, below.

TABLE 8-1.

WASTEWATER FLOW FACTORS

Land Use Wastewater ADWF Factor

Low Density Residential 245 gpd/du

Medium Density Residential 170 gpd/du

High Density Residential 170 gpd/du

Commercial 590 gpd/ac

Industrial 355 gpd/ac

Parks 55 gpd/ac

Schools / Institutional 245 gpd/ac

Wastewater ADWF projections were calculated as the sum of two major components of

future wastewater flow: (1) the volume of wastewater that best represents existing

wastewater generation in the City, and (2) the anticipated wastewater generation associated

with future development projects and planning areas.



The City’s existing wastewater generation is representative of development within the City

as of the end of 2016 and was calculated as the sum of (1) the City’s 2013 daily wastewater

flow, selected as the representative baseline year, with a ten percent safety factor, and (2)

estimated wastewater generation for existing development built between 2013 and the end

of 2016. As shown on Table F-1, the total existing ADWF is estimated to be 1.7 million

gallons per day (MGD).

Wastewater generation associated with anticipated future development is estimated using

the updated wastewater flow factors and the anticipated acreages and number of dwelling

units associated with each proposed development. Table F-2 summarizes the City’s

projected wastewater generation by sector and by development area in five-year increments

between 2020 and 2040 and at buildout, based on development projections. Based on these

projections, it is anticipated that total ADWF in 2040 will be 5.69 MGD, whereas the

ADWF at Buildout is estimated to be 7.07 MGD. Of these totals, ADWFs of 1.39 MGD

and 1.47 MGD are anticipated to flow to MWQCF in 2040 and at buildout, respectively.

ADWFs of 4.29 MGD in 2040 and 5.61 MGD at buildout are projected to flow to the CTF.

A peaking factor was developed based on the City’s historical wastewater flow data to best

estimate PWWF, as shown on Figure 8-1. The PWWF peaking factors are typically higher

in smaller drainage areas, in which there is little flow attenuation. Larger drainage areas

provide a greater capacity to attenuate flows, as peak flows generated in the upstream

reaches of the system take a longer amount of time to travel downstream. The

methodologies used to develop this curve are described in the draft WWSMP.

Modeled PWWF at each pump station are summarized in Table F-3.



FIGURE 8-1

AVERAGE DRY WEATHER FLOW AND PEAKING FACTORS

Design Criteria

The capacity design criteria used to evaluate the City’s existing collection system are

summarized below:

• Gravity mains 15 inches in diameter and smaller are designed for peak flows with

a maximum depth to diameter (d/D) ratio of 0.50. Gravity mains 18 inches in

diameter and larger are designed for peak flows at a maximum d/D ratio of 0.75.

• Maximum velocity in force mains is designed to be less than 10 fps during peak

flows.

• Pump stations should be designed to convey PWWF within its firm capacity3.

Hydraulic Model

The hydraulic capacity evaluation was conducted using a hydraulic model. The hydraulic

model was developed using the Innovyze InfoSWMM modeling platform, a GIS-based

hydraulic modeling software. To optimize the model building and maintenance process, a

key objective of the modeling effort was to construct hydraulic models that are integrated

with the City’s infrastructure GIS (as described in Element 4) and allow for automatic

3 Defined as pumping capacity with the largest pumping unit out of service.

0.0

1.0

2.0

3.0

4.0

5.0

6.0

0 500,000 1,000,000 1,500,000 2,000,000

Pea

k W

et W

eath

er F

low

/ A

vera

ge D

ry W

eath

er F

low

Average Dry Weather Flow (gpd)

Peaking Factor = e(-5.4*ADWF(mgd)+1.5)+2.2



synchronization between the model and infrastructure GIS to limit future maintenance

efforts.

The hydraulic modeling approach for capacity evaluation included (1) conducting steady-

state model simulations of PWWF conditions, and (2) evaluation of capacity and head

requirements at PWWF for each lift station or pump station for existing, and future

development scenarios. These scenarios include: Existing (2016), Near-Term Future

(2025), Long-Term Future (2040), and Selected Buildout (beyond 2040). The Selected

Buildout scenario includes buildout of the Central Lathrop Specific Plan (CLSP) and the

South Lathrop Specific Plan (SLSP) that are anticipated to occur after 2040 to evaluate

regional infrastructure needs for full buildout of CLSP and SLSP, respectively.

Capacity Evaluation Results

Model results have shown that approximately 7% of City’s existing gravity mains will not

meet the capacity criteria by 2040. Areas with capacity deficiencies are mostly consistent

in all scenarios, indicating that most capacity deficiencies identified in the future scenarios

already exist given the estimated existing PWWF, although the degree of deficiency may

increase with projected development. In addition, capacity deficiencies are identified in the

Stonebridge LS and Woodfield LS in all scenarios.

The City’s existing and planned force mains are able to convey projected wastewater flow

beyond 2040.

8.4 Recommended Capacity Projects

The City’s five-year Capital Improvement Program identifies scheduled wastewater CIPs

on the City’s website at http://www.ci.lathrop.ca.us/pwd/cip.aspx.

The draft WWSMP recommended additional CIPs to address the potential deficiencies

identified in the hydraulic assessment discussed in Section 8.3. Table F-4 summarizes all

the WWSMP-recommended collection system CIPs, including location, priority, proposed

improvements, estimated planning level costs, and alternatives. As shown in Table F-4 and

seen on Figure F-1, total Opinion of Probable Cost (OPC) for the recommended collection

system CIPs over the 20-year planning horizon is approximately $12 million.

The City is in the process of conducting a temporary flow monitoring study to evaluate

actual wastewater flow compared to the draft WWSMP estimates, assess I&I across the

City, and assess the WWSMP-recommended CIPs. Findings of this study will be

incorporated into the Final WWSMP.

8.5 CIP Schedule

The City’s five-year Capital Improvement Program identifies the implementation schedule

and funding sources for collection system CIPs.

The five-year Capital Improvement Program will be updated to incorporate WWSMP

recommendations. The draft WWSMP prioritized recommended CIPs based on the timing

and the level of deficiency the CIPs are designed to address. Given that the majority of the

http://www.ci.lathrop.ca.us/pwd/cip.aspx



identified CIPs address deficiencies in the existing collection system, the CIPs have been

prioritized in the following order: (1) projects addressing existing deficiencies with

modeled surcharging, (2) projects addressing other existing deficiencies, and (3) projects

addressing deficiencies associated with future flows.

8.6 Financial and Economic Analysis

The City maintains a five-year CIP which is regularly updated based on the system’s

capacity evaluation and is the basis for establishing new sewer rates. Funding for the City’s

capacity CIPs are sourced from developers if they are due to planned new development, or

from the City’s Sewer Capital Replacement Fund if it is related to an existing deficiency.

Element 9: Monitoring, Measurement, & Program Modifications


ELEMENT 9: MONITORING, MEASUREMENT, & PROGRAM MODIFICATIONS This section of the SSMP discusses parameters the City tracks to monitor the success of

the SSMP and how the City plans to keep the SSMP current. This section fulfills the

Monitoring, Measurement, and Program Modifications requirement for the SWRCB

(Element 9) SSMP requirements.

9.1 Regulatory Requirements for Monitoring, Measurement, & Program Modifications

9.2 Element 9 Appendix G

Supporting information for Element 9 is included in Appendix G. This appendix includes the

following documents:

1. SSMP Monitoring Tracking Sheet

2. SSMP Change Log

9.3 Monitoring and Measurement Discussion

The City tracks several performance measures through tracking logs and annual reports,

including but not limited to number, cause, location, and volume of SSOs; SSO response time;

length of pipe cleaned, inspected, and type of debris found; number of FSEs inspected; and the

type and attendance of staff training. The City plans to continue tracking all performance

measures that are currently tracked.

In order to monitor the effectiveness of the SSMP, however, the City has selected certain,

specific parameters that can be documented and compared on an annual basis in a simple

format. These parameters were selected because they are straightforward, quantitative, and

focused on results. Although the parameters may not track everything associated with SSMP

D.13.(ix) Monitoring, Measurement, and Program Modifications: The Enrollee shall:

a) Maintain relevant information that can be used to establish and prioritize appropriate

SSMP activities;

b) Monitor the implementation and, where appropriate, measure the effectiveness of

each element of the SSMP;

c) Assess the success of the preventative maintenance program;

d) Update program elements, as appropriate, based on monitoring or performance

evaluations; and

e) Identify and illustrate SSO trends, including: frequency, location, and volume.

MRP Section E.3 – Records documenting all changes made to the SSMP since its last

certification indicating when a subsection(s) of the SSMP was changed and/or updated and

who authorized the change or update. These records shall be attached to the SSMP.



implementation, changes in these parameters over time will indicate the overall success of the

SSMP or, conversely, underlying problems that can then be investigated further.

Table 9-1 lists each SSMP element, the overall purpose of the SSMP element, and the specific

parameters that the City plans to track that will help in evaluating the effectiveness of the

SSMP. Appendix H includes a tracking sheet listing each of these parameters, which the City

will fill out annually in conjunction with completing the SSMP audit (Element 10).

Table 9-1. SSMP Monitoring Parameters, by SSMP Element

SSMP Element Summary of Element Purpose Parameters for Tracking

Effectiveness (Annual)

4 - Operations and

Maintenance

Program

Minimize blockages and SSOs by

properly operating and maintaining

the system.

• Total number and

volume of SSOs

• Total amount recovered

• Total amount estimated

to reach surface waters

• Percent reaching surface

water

• Total length of pipe

CCTV’d


hydrocleaned


repaired or replaced

6 - Overflow

Emergency

Response Plan

Provide timely and effective

response to SSO emergencies and

comply with regulatory reporting

requirements

• Percent of total SSO

volume contained or

returned to sewer

7 - Fats, Oils, &

Grease Control

Program

Minimize blockages and SSOs due

to FOG • Number of SSOs due to

FOG

• Number of blockages

due to FOG

• Number of FSEs

inspected

The City will use the specific tracked parameters listed in Table 9-1 and documented on

the tracking sheet included in Appendix G to assist in completion of the annual SSMP

Audit described in Element 10. As noted above, the City will also continue to collect data

for all performance measures currently tracked. This additional information that the City

collects, such as customer complaints and length of pipe cleaned, will be used to support

or further evaluate the successes and limitations of the SSMP as needed.



9.4 SSMP Modifications

The SSMP needs to be updated periodically to maintain current information, and programs

need to be enhanced or modified if they are determined to be less effective than needed. The

City will review the successes and needed improvements of the SSMP as part of the SSMP

annual audit, described in Element 10.

City staff will update critical information, such as contact numbers and the SSO response chain

of communication, as needed. A comprehensive SSMP update will occur every 5 years, as

required by the SWRCB. The City will schedule this SSMP update to occur in conjunction

with the WWSMP update. All changes made to the SSMP shall be listed in the SSMP Change

Log in Appendix G.

Element 10: SSMP Program Audits


ELEMENT 10: SSMP PROGRAM AUDITS This section of the SSMP discusses the City’s SSMP auditing program. This section fulfills

the SWRCB (Element 10) SSMP Audit requirements.

10.1 Regulatory Requirements for SSMP Audits

10.2 Element 10 Appendix H

Completed SSMP audits are stored in Appendix H.

10.3 SSMP Audits Discussion

The City will complete audits of its SSMP every two years, and will prepare a report to be

kept on file. The audit will include the following:

• Review of progress made on development of SSMP elements;

• Review of monitoring and measurement tracked under Element 9;

• Identification of successes of implementing SSMP elements and needed

improvements;

• Description of system improvements during the audit period; and

• Description of system improvements planned for the upcoming two years,

with an estimated schedule for implementation.

Upon completion of the audit, the City will keep a report of the audit on file to fulfill the

SWRCB audit requirement. A copy of the last 3 audits will be stored in Appendix H of the

SSMP. Modifications and changes to the SSMP will be identified and tracked by the SSMP

Change Log and included in Appendix H. This log will be used to track SSMP changes in

the periods between audits as well as changes made as a result of audits or SSMP updates.

A copy each audit will be stored in Appendix H of the SSMP.

D.13.(x) SSMP Program Audits - As part of the SSMP, the Enrollee shall conduct periodic

internal audits, appropriate to the size of the system and the number of SSOs. At a minimum,

these audits must occur every two years and a report must be prepared and kept on file. This

audit shall focus on evaluating the effectiveness of the SSMP and the Enrollee’s compliance

with the SSMP requirements identified in this subsection (D.13.), including identification of

any deficiencies in the SSMP and steps to correct them.



ELEMENT 11: COMMUNICATION PROGRAM This section of the SSMP discusses the City’s communications with the public and satellite

agencies. This section fulfills the Communication Program requirement for SWRCB (Element

11).

11.1 Regulatory Requirements for Communication Program

11.2 Element 11 Appendix I

Supporting information for Element 11 is included in Appendix I. This appendix includes


1. Copy of Public Notification Posted on City’s Website.

11.3 Communication Program Discussion

The City will communicate with the public on the development, implementation, and

performance of its SSMP by placing notices on the City’s website. Additionally, flyers will

be posted at City Hall announcing the availability of the SSMP to the public, upon request.

Public comments are welcomed during the development, implementation, and performance

of the SSMP. Public comments will be directed to the PWD’s phone number at (209) 941-

7430. Comments will be forwarded to the administrative staff responsible for oversight of

the SSMP.

The City maintains an open line of communication with City of Manteca per the City’s

Interjurisdictional Agreement with Manteca, because a portion of the sewer flows from the

City are directed to the MWQCF.

D.13.(xi) Communication Program. The Enrollee shall communicate on a regular basis with

the public on the development, implementation, and performance of its SSMP. The

communication system shall provide the public the opportunity to provide input to the Enrollee

as the program is developed and implemented.

The Enrollee shall also create a plan of communication with systems that are tributary and/or

satellite to the Enrollee’s sanitary sewer system.

APPENDIX A – Element 2 (Organization)

City of Lathrop Sewer System Management Plan A-1

APPENDIX A – Element 2 (Organization) Supporting Documents

1. Figure A-1. Organization Chart of Wastewater Utility Staff

2. Description of General Responsibilities for Wastewater Utility Staff

3. Table A-1. Names and Telephone Numbers of Staff Responsible for SSMP

4. Table A-2. List of City Staff Responsible for SSMP Elements



Figure A-1 Organization Chart of Wastewater Utility Staff

City Council

City Attorney City Manager

Director of Public Works

Administration

Project Support

Projects & Programs Manager

Admin/Fiscal Support

Sr. Management Analyst

Sr. Administrative Assistant

Administrative Assistant II (0.33)

Construction

Sr. Construction Inspector

Operations and Maintenance

Superintendent

Maintenance Division

Maintenance Supervisor

Sr. Maintnenace Worker

Maintenance Worker

Utilities Operation Division

Utility Operator

Meter Reader

Engineering

Principal Engineer

Sr. Civil Engineer

Assistant Engineer

Building

Chief Building Official

Building Inspector I/II

Sr. Administrative Assistant (0.67)

Permit Technician

Code

Code Compliance Supervisor

Code Compliance Officer

Director of Finance



Description of General Responsibilities

City Manager: Under policy direction, serves as the Chief Administrative Officer of the City and

directs the activities and operation of all departments; advises and assists the City Council in the

conduct of City business; provides administrative oversight to the operational and policy functions

of City government; coordinates City business with various programs, officials and outside

agencies; provides a variety of other responsible and complex administrative support to the City

Council; performs other related duties as required.

Public Works Director: Plans, organizes, directs, and supervises the public works activities of the

City; advises the City Council and Planning Commission on engineering and public works matters,

including those related to the collection system. Prepares and controls department budget; reviews

project plans and specifications for public works projects and performs technical engineering

planning studies; confers with engineering consultants and officials of other public works

departments.

Operations & Maintenance Superintendent: Plans, organizes, and supervises the maintenance and

repair of City public works infrastructure, including sewers; manages the Municipal Service

Center. Reviews plans and specifications for sewer and other projects, and makes

recommendations regarding maintenance, construction, and operations aspects. Controls budget

expenditures within the Maintenance Division; confers with contractors, engineers, and members

of the general public on construction and maintenance problems and procedures.

Maintenance Supervisor: Under general direction of the Public Works Superintendent, supervises,

coordinates, directs and evaluates the work of staff involved in the operation, maintenance and

repair of the City’s water distribution, wastewater collection and storm drain systems; assists in

the research and implementation of new programs; ensures safe work practices, work quality and

accuracy; maintains appropriate work records which may include time cards and work orders;

serves as a technical resource for assigned staff; performs other related duties as required.

Senior Maintenance Worker: To lead, oversee, and participate in the work of maintenance crews

responsible for Public Works Services including street maintenance, street painting, traffic signs,

gutter and sidewalk repair; to assist with sewer and storm drain maintenance; and to perform a

variety of technical tasks relative to assigned areas of responsibility.

Maintenance Worker: Works as a member of a field maintenance crew; cleans, unplugs, and

repairs sewer lines; locates and raises manholes; operates power equipment including hydraulic

cleaning truck and sewer rodder.

Utility Operator: Under general supervision, learns to perform and performs the full array of duties

assigned to classes in the Utility Operator series, including skilled and semi-skilled work in the

operation, maintenance and repair of the City’s water distribution, sewer collection and storm drain

systems; assists other units of Public Works in the maintenance of streets, facilities and buildings

as needed; demonstrates a full understanding of all applicable policies, procedures and work

methods associated with assigned duties; performs other related duties as required.



Principal Engineer: Under direction of the Public Works Director or City Engineer, supervises,

evaluates and participates in professional and technical civil engineering work in the planning,

design, construction and maintenance of the City’s Capital Improvement Projects, streets, storm

drain facilities, landscape, lighting, sanitary sewer facilities, parks, water production and

distribution facilities, buildings and other projects; ensures safe work practices, work quality and

accuracy; maintains appropriate work records; serves as a technical resource for assigned work

staff; performs other related duties as required.

Senior Civil Engineer: To plan, direct, manage and oversee Public Works utilities activities,

including water and wastewater systems/plants; to coordinate water and wastewater projects,

development review, and/or master plans, and assigned activities with other divisions,

departments, consultants, contractors, engineers, and outside agencies; and to provide highly

responsible and complex administrative support to the Public Works Director.

Associate Engineer: To perform professional engineering work in connection with design,

inspection, and development review projects; to perform advanced sub-professional engineering

work including contract administration, traffic engineering duties, and public works inspection; to

assist the coordination of capital improvement projects, development review, and/or master plans,

and assigned activities with other departments, divisions, consultants, contractors, engineers, and

outside agencies; and to provide responsible and professional engineering support to the Public

Works Department.

Senior Construction Inspector: Performs all Construction Inspector duties, including the most

complex paraprofessional engineering, office and field work involving inspection, field testing and

surveying; provides lead direction and work instruction to assigned construction inspection staff;

acts as a technical expert and serves as lead in providing in-office customer service to the public

and other departments; provides responsible staff assistance to the Principal Engineer or the

Director of Public Works/City Engineer.

Project and Programs Manager: Under direction of the Public Works Director or the Assistant City

Manager, plans, supervises, evaluates and participates in professional work in the planning, design,

construction, maintenance and programming of services of Public Works Capital Improvement

Projects, public facilities, utilities, and other projects; performs complex analysis of project costs

and monitoring project progress; assists in the preparation and administration of department

budgets, ensures safe work practices, work quality and accuracy; and maintains appropriate work

records.

Senior Administrative Assistant: To perform a variety of supervisory responsibilities overseeing

clerical support staff of the department; perform confidential and complex administrative duties

where knowledge of the organization, personnel policies and procedures are essential.

Administrative Assistant: Under general supervision, learns to perform and performs routine and

complex tasks and duties assigned to classes within the Administrative Assistant series by

providing office, clerical and administrative support to management staff, and other staff, in one

or more departments as needed; interprets and applies policies, procedures and work methods

associated with assigned duties; performs other related duties as required.



Budget Analyst I/II: Under direction, performs a wide variety of professional, administrative,

human resources, analytical and management support within assigned program areas; develops,

implements and administers assigned program responsibilities, including budget preparation,

financial management and grant coordination; conducts research; performs other related duties as

required.



Table A-1. Names and Phone Numbers of Staff Responsible for SSMP

Contact Phone Number Email Address

Public Works Director (209) 941-7499 -

Milton Daley, O&M

Superintendent

(209) 941-7475 [email protected]

Phil Humphrey, Utility

Operator


Chris Hart, Utility Operator (209) 992-0019 [email protected]

Michael Dunn, Utility

Operator


Ian Zeiher, Utility Operator (209) 993-9615 [email protected]

Henry Hernandez, Utility

Operator


Aurelio Rodriguez, Senior

Maintenance Worker


Robert McGinnis, Senior

Construction Inspector


Jay Davidson, Principal

Engineer


Greg Gibson, Senior Civil

Engineer


Michael King, Senior Civil

Engineer


Ken Reed, Projects Manager (209) 992-0733 [email protected]

Emilia Knox, Senior Admin

Assistant


Veronica Hedges, Admin

Asst.


Paul Zolfarelli, VWNA

(Plant Manager)




Table A-2. List of City Staff Responsible for SSMP Elements

SSMP Element Responsible Position(s)

I. Goals Public Works Director

II. Organization Public Works Director

III. Legal Authority Public Works Director;

City Attorney

IV. Operations & Maintenance O&M Superintendent

V. Design and Construction Standards Senior Civil Engineer;

Senior Construction Inspector

VI. Overflow Emergency Response Plan O&M Superintendent

VII. FOG Control Program O&M Superintendent,

VWNA

VIII. System Evaluation and Capacity Assurance Senior Civil Engineer

IX. Monitoring, Measurement, and Program

Modifications

Senior Civil Engineer

Administrative Assistant

X. SSMP Program Audits Senior Civil Engineer

XI. Communication Administrative Assistant

Appendix B - Element 3 (Legal Authority)

City of Lathrop Sewer System Management Plan B-1

APPENDIX B – Element 3 (Legal Authority) Supporting Documents

1. Enforcement Response Plan – Enforcement of Sewer Use Ordinance

2. Enforcement Response Plan – Fats, Oils & Grease Source Control Program

3. Interjurisdictional Agreement Between the City of Manteca and The City of Lathrop.

City of Lathrop, California

ENFORCEMENT RESPONSE PLAN

Enforcement of Sewer Use Ordinance #05-254

Chapter 13, Section 26 of the Lathrop Municipal Code

[Industrial Pretreatment Regulations]

City of Lathrop


Contents

I. INTRODUCTION ........................................................................................................................1

A. Introduction .....................................................................................................................1

B. Personnel Assignments: ..................................................................................................1

C. Reference .........................................................................................................................1

II. ENFORCEMENT PROVISIONS OF THE SEWER USE ORDINANCE .................................2

III. ENFORCEMENT RESPONSE MATRIX ................................................................................4

A. Description of Terms ......................................................................................................4

Lathrop Enforcement Response Matrix ...............................................................................7

IV ENFORCEMENT RESPONSES ..............................................................................................14

A. Levels of Response .......................................................................................................14

B. Descriptions of Enforcement Actions ...........................................................................15

1. Notice of Violation ............................................................................................15

2. Administrative Order .........................................................................................16

3. Show Cause Hearing ..........................................................................................18

5. Termination of Discharge ..................................................................................18

6. Administrative Fines ..........................................................................................19

4. Emergency Suspensions .....................................................................................20

7. Civil Penalties ....................................................................................................20

8. Criminal Penalties ..............................................................................................20

9. Supplemental Enforcement Responses ..............................................................21

C. Enforcement Order Format ...........................................................................................21

D. Procedures .....................................................................................................................22

E. Tracking Enforcement Related Situations .....................................................................23

F. Assessment of Administrative Fines .............................................................................23

1. Purpose ...............................................................................................................23

2. Legal Authority ..................................................................................................23

3. When to Assess Administrative Fines ...............................................................24

4. Determining the Amount of the Fine .................................................................24

5. Method of Assessing Administrative Fines .......................................................25

G. Termination of Sewer Service .......................................................................................25

1. General Discussion ............................................................................................25

2. Legal Authority ..................................................................................................26

3. When to Terminate Service ...............................................................................26

H. Publication ....................................................................................................................27

APPENDIX A SAMPLE ENFORCEMENT DOCUMENTS .......................................................28

City of Lathrop ERP page 1

City of Lathrop


I. INTRODUCTION

A. Introduction

In an effort to uniformly and consistently implement the provisions of the Lathrop Sewer Use

Ordinance, Chapter 13.26 of the Lathrop Municipal Code (LMC), the Enforcement Response

Plan (ERP or Plan) provides the guidelines for investigating and responding to industrial user

noncompliance. This ERP has been developed for guidance and is not intended to create

legal rights or obligation or to limit the enforcement discretion of any of the administering

agencies.

The centerpiece of this Plan is the Enforcement Response Matrix included in Part III, which

lists potential violations and corresponding ranges of appropriate enforcement options. The

purpose of the guide is to promote consistent and timely enforcement responses, as well as to

eliminate uncertainty and confusion concerning enforcement. Detailed descriptions of the

enforcement responses available to the City and guidelines for their implementation are

provided Part IV.

B. Personnel Assignments:

The following are the titles of those persons involved in the implementation and enforcement

of the Lathrop Sewer Use Ordinance:

Director of Public Works - 209-941-7430

City Attorney - 209-941-7235

Veolia Water NA Project Manager - 209-858-1645

City Pretreatment Coordinator - 209-858-1645

C. Reference

U.S. Environmental Protection Agency’s (EPA’s) Pretreatment Compliance Monitoring and

Enforcement Guidance, July 1986 was used in the development of this Plan. For additional

information and general discussions about other enforcement actions not discussed in this

Plan, refer to the EPA Guidance for Developing Control Authority Enforcement Response

Plans, U.S. EPA, 1989; and EPA Introduction to the National Pretreatment Program, March

2011.


II. ENFORCEMENT PROVISIONS OF THE SEWER USE ORDINANCE

All pretreatment program regulations as required by 40 CFR 403.8 are contained in LMC

Chapter 13, Section 26 (City Sewer Use Ordinance #05-254). The following table summarizes

the ordinance provisions that satisfy the requirements of the Industrial Pretreatment Program.

Federal Code

(40 CFR

403.8(f))

Pretreatment Topic City Sewer Use Ordinance Provision

(1) i Deny or Condition § 13.26.010.B. Authority to Require Pretreatment

ii Comply with Standards § 13.26.010.A. Objectives

§ 13.26.030.A. Pretreatment Facilities

§ 13.26.030.B. Additional Pretreatment Measures

§ 13.26.050 Permit Conditions

iii Comply with Standards § 13.26.010.A Purpose & Policy

§ 13.26.020.A General Sewer Use Requirements

§ 13.26.050 Wastewater Discharge Permits

a Duration § 13.26.050.G. Permit Duration

§ 13.26.050.H. Permit Contents

b Transferability § 13.26.050.K. Permit Transfer

c Effluent Limits § 13.26.050.H Permit Contents

d Self-Monitoring § 13.26.050.H Permit Contents

e Civil & Criminal Penalties § 13.26.110 Administrative Enforcement

Remedies

§ 113.26.120 Judicial Enforcement Remedies

§ 13.26.130 Supplemental Enforcement Actions

§ 13.26.140 Affirmative Defenses to Discharge

Violations

§ 13.26.150 Pretreatment Charges & Fees

§ 13.26.160 Fat, Oil & Grease Control Program

iv a Compliance Schedules § 13.26.050.H. Permit Contents

§ 13.26.060 Reporting Requirements

b Monitoring Reports § 13.26.050.H Permit Contents

§ 13.26.060.e. Reporting Requirements

v Inspections § 13.26.050.H. Permit Contents

§ 13.26.070 Monitoring Requirements

§ 13.26.070.A. Right of Entry

§ 13.26.160. Fat, Oil & Grease Control Program

vi a Injunctive Relief

Civil or Criminal

Penalties

§ 13.26.120.A. Injunctive Relief

§ 13.26.120.B. Civil Penalties

§ 13.26.120.C. Criminal Penalties


Federal Code

(40 CFR

403.8(f))

Pretreatment Topic City Sewer Use Ordinance Provision

b Halt Discharges § 13.26.110.E. Cease & Desist Order

§ 13.26.110.G. Emergency Suspension

§ 13.26.110.H. Termination of Discharge

§ 13.26.130.C. Water Supply Severance

vii Confidentiality § 13.26.080 Confidential Information

(2) i Identify & Locate § 13.26.040 User Survey

§ 13.26.050.D. Discharge Permit Application

ii Characterize § 13.26.050.D. Discharge Permit Application

§ 13.26.050.H. Discharge Permit Contents

§ 13.26.060.B. Categorical Baseline Monitoring

Report

§ 13.26.060.E. Periodic Compliance Report

§ 13.26.060.J. Notification of the Discharge of

Hazardous Waste

iii Notify User § 13.26.020 General Sewer Use Requirements

§ 13.26.050.H Permit Contents

§ 13.26.060.J. Notification of the Discharge of

Hazardous Waste

iv Receive Reports § 13.26.050.H Permit Contents

§ 13.26.060 Reporting Requirements

v Random Sampling

Slug Discharges

§ 13.26.030.C. Accidental Discharge/Slug

Control Plan

§ 13.26.050.H Permit Contents

§ 13.26.070 Compliance Monitoring

vi Investigate § 13.26.070 Compliance Monitoring

vii Public Participation § 13.26.090 Publication of Users in Significant

Noncompliance

(3) Funding § 13.26.150 Pretreatment Charges and Fees

(4) Local Limits § 13.26.020.D. Local Limits

(5) Enforcement Response

Plan

§ 13.26.100 Enforcement Response Plan

(6) Industrial User List § 13.26.040 User Survey


III. ENFORCEMENT RESPONSE MATRIX

A. Description of Terms

CA - City Attorney

Civil Litigation - Civil action against the industrial user seeking equitable relief, monetary

penalties, and actual damages.

Criminal Penalties - Pursuing punitive measures against an individual and/or organization

through a court of law.

Consent Orders - An order issued against an IU to assure voluntary compliance, or similar

documents establishing an agreement for compliance.

DPW - Director of Public Works

Fine - Monetary penalty assessed by Control Authority officials.

IU -Industrial User as defined in the City of Lathrop Pretreatment Ordinance

Meeting - Informal compliance meeting with the IU to resolve recurring noncompliance

NOV - Notice of Violation

PC -Pretreatment Coordinator

POTW – Publicly owned treatment works

S - Veolia Water NA Project Manager

Show Cause Hearing - Formal meeting requiring the IU to appear and demonstrate why the

Control Authority should not take a proposed enforcement action against it.

The meeting may also serve as a forum to discuss corrective actions and

compliance schedules.

Significant Noncompliance - An industrial user is in significant noncompliance if its

violation meets one or more of the following criteria:

1. Chronic violations of wastewater discharge limits, defined here as those in

which sixty-six percent (66%) or more of wastewater measurements

taken during a six (6) month period exceed the daily maximum limit

or the average limit for the same pollutant parameter by any amount;

2. Technical Review Criteria (TRC) violations, defined here as those in


which thirty-three percent (33%) or more of wastewater

measurements taken for each pollutant parameter during a six (6)

month period equals or exceeds the product of the daily maximum

limit or the average limit multiplied by the applicable criteria (1.4 for

BOD, TSS, fats, oils and grease, and 1.2 for all other pollutants

except pH);

3. Any other discharge violation that the City believes has caused, alone or

in combination with other discharges, interference or pass through,

including endangering the health of POTW personnel or the general

public;

4. Any discharge of pollutants that have caused imminent endangerment to

the public or to the environment, or have resulted in the City’s

exercise of its emergency authority to halt or prevent such a

discharge;

5. Failure to meet, within ninety (90) days of the scheduled date, a

compliance schedule milestone contained in a wastewater discharge

permit or enforcement order for starting construction, completing

construction, or attaining final compliance;

6. Failure to provide within forty-five (45) days after the due date, any

required reports, including baseline monitoring reports, reports on

compliance with categorical pretreatment standard deadlines, periodic

self-monitoring reports, and reports on compliance with compliance

schedules;

7. Failure to accurately report noncompliance; or

8. Any other violations(s) which the City determines will adversely affect the

operation or implementation of the local pretreatment program.

Terminate Service - Disconnection of industrial user from sanitary sewer service.

B. Using the Enforcement Response Matrix

This matrix of response actions addresses a broad range of pretreatment violations. It is not

intended to cover every possible violation. The responses in this plan are suggested

responses; the City may have alternative enforcement responses that are equally effective.

When the City elects to pursue an enforcement course that is significantly different from the

suggested course in the enforcement matrix, the City should prepare a statement explaining

the intent and the basis for the actions taken. The enforcement response matrix is used as

follows:


(1) Locate the type of noncompliance in the first column and identify the most accurate

description of the violation in column 2.

(2) Assess the appropriateness of the recommended response(s) in columns three and four

using the criteria of magnitude, duration, effects, compliance history, and good faith.

(3) Apply the enforcement response to the industrial user, specifying corrective action(s) or

other responses required of the industrial user. Column five indicates responsible

personnel.

(4) Track industrial user's response and follow-up with escalated enforcement action if a

response is not received or violation continues.


LATHROP ENFORCEMENT RESPONSE MATRIX

Noncompliance Nature of Violation Violation

Category

Enforcement Response Authority

Unauthorized

Discharge

IU unaware of requirements; NO

harm to POTW or environment.

0 Phone call. NOV with application form attached to be

submitted within 45 calendar days. Application deadline to

be specified in the NOV.

PC

IU unaware of requirements;

HARM to POTW or environment

is evident.

(SIGNIFICANT

NONCOMPLIANCE)

3 a. Cease & Desist Order. Compliance Order requiring

submittal of a permit application within 45 calendar days

and assessing any penalties or recovery of damages and

costs.

DPW

S

4 b. Termination of Service and Civil Litigation or Criminal

Investigation.

DPW

CA

IU has not submitted permit

application by deadline.

0 NOV for missed deadline requiring submittal within 15

calendar days or further enforcement action will be pursued.

PC

IU has not submitted application

within 15 calendars days of date

specified in NOV.

(SIGNIFICANT

NONCOMPLIANCE)

1 Show Cause Order assessing a penalty per day of violation

and requiring the IU to appear before the DPW to show

cause as to why further enforcement should not be pursued.

Penalty to be assessed from the 16th day forward.

DPW

Failure to submit permit

application continues more than

60 days after receipt of NOV by

the IU.

(SIGNIFICANT

NONCOMPLIANCE)

4 Civil Litigation and Termination of Service. DPW

CA



Category


Discharge Limit

Violation

(Local and/or

Federal)

Type A- exceed one or more daily

or average parameter limits by less

than a factor of 3.0.

0 NOV detailing violation and requiring repeat sampling and

analysis within 45 days of becoming aware of the violation

and submit results to PC.

PC

Type B- exceed one or more daily

or average parameter limits by a

factor of 3.0 or greater.

(SIGNIFICANT

NONCOMPLIANCE)

1 NOV detailing violation and requiring correction within 30

business days. IU must repeat sampling and analysis within

45 days of becoming aware of the violation and submit

results to PC. Penalties to be assessed by Compliance Order

for each day of violation.

DPW

PC

Type C- Chronic and/or TRC

violation as defined by EPA.

(SIGNIFICANT

NONCOMPLIANCE)

2 Show Cause Order assessing a penalty per violation per day


cause why further enforcement should not be pursued.

Further actions (if warranted) will be addressed in a

Compliance Order.

DPW

Type D- violation of any daily or

average parameter limit which

adversely affects the POTW.

Interference, inhibition, or pass-

through.

(SIGNIFICANT

NONCOMPLIANCE)

3 Cease and Desist Order requiring the IU to halt the violation

immediately or terminate the discharge altogether.

Compliance Order assessing any penalties and/or cost

recovery.

DPW

S

Reporting

Violations

Report is improperly signed or

certified.

0 Phone Call. PC


certified after phone call by

POTW.

0 NOV requiring correction on the next report. PC


certified after issuance of NOV by

POTW.

(SIGNIFICANT

NONCOMPLIANCE)

1 Compliance Order assessing a penalty and requiring the IU

to properly sign or certify the next regularly scheduled

report.

DPW



Category


Report late by less than 30

calendar days.

0 NOV for missed deadline. PC

Report late 30 calendar days or

more.

1 Informal meeting between the IU and the Pretreatment

Coordinator. NOV requiring report submittal no later than

45 days from the original report deadline.

DPW

PC


more.

(SIGNIFICANT

NONCOMPLIANCE)

2 Show Cause Order assessing a penalty per day of violation



DPW


more.

(SIGNIFICANT

NONCOMPLIANCE)

3 Compliance Order requiring IU to submit the required

report within 15 calendar days.

DPW


more.

(SIGNIFICANT

NONCOMPLIANCE)

4 Civil Litigation. DPW

CA

Failure to report SPILLS or

CHANGED DISCHARGE. NO

harm to POTW or environment.

Isolated incident.

1 NOV and Compliance Order requiring the IU to develop

and implement a spill prevention plan by a specified

deadline.

PC

Failure to report SPILLS or

CHANGED DISCHARGE. Harm

to the POTW or environment.

(SIGNIFICANT

NONCOMPLIANCE)

2 Cease and Desist Order requiring IU to halt the illegal

discharge immediately or terminate its discharge altogether.

Compliance Order assessing a penalty per day of violation

and addressing cost recovery.

DPW

Repeated failure to report SPILLS.

(SIGNIFICANT

NONCOMPLIANCE)

3 Show Cause Order assessing a penalty per incident and

requiring the IU to appear before the DPW to show cause

why further enforcement should not be pursued.

DPW



Category


Inadequate

Recordkeeping

Pretreatment Coordinator finds

files incomplete or missing (no

evidence of intent).

0 NOV explaining the required recordkeeping and

documentation.

PC

Recurring incidence of files

incomplete or missing.

1 Compliance Order requiring proper maintenance of records.

Assessment of penalty to be issued on severity of violation.

DPW

Failure to Report

Additional

Monitoring

Pretreatment Coordinator finds

additional files.

0 NOV requiring submittal of additional monitoring. PC

Recurring failure to report

additional files (considered

falsification).

3 Compliance Order requiring submittal of all additional

monitoring. Assessment of a penalty to be based on the

severity of the violation.

DPW

Falsification

First occurrence. (SIGNIFICANT

NONCOMPLIANCE)

1 Show Cause Order requiring IU to appear before the

Director to show cause why enforcement action should not

be pursued.

DPW

Subsequent occurrences.

(SIGNIFICANT

NONCOMPLIANCE)


CA

Improper

Monitoring

Failure to monitor all pollutants as

required by IU's Permit.

0 Informal meeting with IU to review required sampling and

reporting.

PC

Failure to monitor all pollutants as

required by IU's Permit. (Second

occurrence)

0 NOV requiring complete sampling and analysis with report

due no later than 30 calendar days from receipt of NOV.

PC

Recurring failure to monitor

properly. (Third occurrence)

(SIGNIFICANT

NONCOMPLIANCE))

1 Show Cause Order assessing a penalty for each incidence



DPW



Category


Improper Sampling

(Sample Type,

Sample Location, Or

Collection

Technique)

No evidence of intent. (First

violation)

0 NOV explaining correct procedure and requiring proper

sampling for the next self-monitoring report.

PC

Improper sampling continues.

(Second violation)

0 Informal meeting with IU to review proper sampling

criteria.

PC

Evidence of Intent. (Failure to

properly sample after informal

meeting is viewed as evidence of

intent.) (SIGNIFICANT

NONCOMPLIANCE)

1 Show Cause Order assessing a penalty for each incidence.

Order requires IU to appear before the DPW to show cause

why further enforcement should not be pursued.

DPW

Failure to Install

Monitoring

Equipment as Set

forth in IU Permit

or Compliance

Order

Missed final installation deadline. 0 NOV requiring complete installation within 30 calendar

days of receipt of NOV.

PC

Noncompliance with NOV.

(Delay of more than 45 calendar

days) (SIGNIFICANT

NONCOMPLIANCE)

1 Compliance Order requiring final installation by a specified

deadline. Assessment of a daily penalty if the requirements

of this Order are not met.

DPW

Compliance

Schedules (In a

Permit or Order)

Missed interim milestone date by

less than 30 days will not affect

final compliance deadline.

0 NOV which restates any remaining milestone deadlines. PC


less than 30 days and will affect


1 Compliance Order detailing revised compliance schedule.

Order may assess fines if delay was avoidable (no good

cause).

DPW


more than 30 days, and will not

affect final compliance deadline.

0 Informal meeting with IU to review compliance schedule,

milestone dates, and final compliance deadline.

DPW


more than 30 days, and will affect


1 Show Cause Order requiring IU to appear before the DPW

to show cause why further enforcement should not be

pursued. Must result in a revised Compliance Order.

DPW



Category



more than 90 days.

(SIGNIFICANT

NONCOMPLIANCE)


CA

Missed Final

Compliance

Deadline

Failure to comply with an

Administrative Order

4 Compliance Order assessing a penalty per day past the Final

Compliance Deadline and requiring immediate compliance.

DPW

Civil Litigation should be pursued if IU has not complied

within 45 calendar days of the original Final Compliance

Deadline

CA

Waste Streams are

Diluted

Dilution of regulated waste

streams with non-polluted water.

0 NOV citing regulatory prohibition against dilution and

requiring correction within 45 calendar days of receipt of

the NOV

PC

Recurring violations. (DILUTION

continues to occur after NOV)

1 Informal meeting with IU to review Ordinance prohibitions.

Compliance Order with deadline for correction.

DPW

Failure to Mitigate

Noncompliance or

Halt Production

Failure to reduce the severity of

the violation(s) and/or failure to

comply with a Cease and Desist

Order.

4 Civil prosecution seeking an injunction to HALT

DISCHARGE. Termination of Permit and Service if

potential for POTW and/or environmental harm is evident.

DPW

CA

Entry Denial Entry denied or consent

withdrawn. Record access denied.

0 Obtain warrant and return to IU. PC

Illegal Discharge

(Violation of

Standards [40 CFR

403.5(A) And (B)

No harm to POTW or

environment. No Interference or

pass-through at the POTW

0 NOV explaining the General Prohibited Discharge

Standards as contained in 40 CFR 403.5 (a) and (b).

PC

Discharge causes harm, pass-

through, or interference

3 Cease and Desist Order requiring the IU to halt the violation

immediately or terminate the discharge altogether.

Compliance Order assessing any penalties and/or cost

recovery.

DPW

PC

Failure to Properly

Operate and

No violation results from failure

of IU to properly operate &

maintain facility

0 NOV explaining the requirement to properly operate and

maintain pretreatment facilities.

PC



Category


Maintain

Pretreatment

Facility

Violations of Permit or

Pretreatment Standards occur

because of failure of IU to

properly maintain and operate

pretreatment facility.

1 Compliance Order requiring proper maintenance and

operation of pretreatment facility with schedule of

compliance.

DPW

Recurring violation or failure to

meet compliance schedule; no

harm to POTW.

3 Compliance Order requiring proper maintenance and

operation of pretreatment facility with schedule of

compliance. Assessment of a penalty to be based on the

severity of the violation.

DPW

CA

Recurring violation or failure to

meet compliance schedules; harm

to POTW.

4 Civil Litigation. Termination of Permit and Termination of

Service. Assessment of Administrative Fines and Cost

Recovery.

DPW

CA, CM


IV ENFORCEMENT RESPONSES

A. Levels of Response

There are three possible levels of response to all violations available to the City: no response,

an informal response, or a formal response. For any violation, the City must review the

violation and determine the appropriate response. Informal enforcement responses are

commonly used for Category 0 or 1 violations, while formal enforcement responses are

commonly used for Category 2 through 4 violations, as described in the Enforcement

Response Guide in Section III.

Informal enforcement response can be an inspection, phone call, informal meeting, or a

verbal Notice of Violation (NOV) to the industrial user (IU). The NOV can be limited to a

notification of the violation or it can require the IU to take certain steps within specific

timeframes. For some violations, the City may determine that no further actions are

necessary. In other cases, the City may direct the IU to conduct additional sampling; review

of procedures or permit; or conduct additional investigation and develop a plan to prevent

future violations. It is the City’s policy to issue a Notice of Violation for all violations of the

numerical discharge limits setforth in the permit. Informal enforcement actions can be taken

by the Pretreatment Coordinator. However, the City’s Director of Public Works should be

informed or included in the decision making and implementation of the enforcement action.

Formal enforcement responses are specified under the ordinance and include all enforcement

remedies with the exception of a verbal NOV. The City has Administrative Orders, Service

Termination, Criminal and Civil Litigation, and other options available to enforce the City

Sewer Use Ordinance. Formal enforcement actions always require the action of the City’s

Director of Public Works, City Manager, City Attorney, and/or Mayor and Council. Most

enforcement actions are administered by the Director of Public Works as authorized by the

duties and responsibilities of his position. For those enforcement actions that involve a court

action, the City Attorney and City Manager retain the authority to initiate actions as specified

by the City.

Violations of monitoring, reporting, and treatment requirements may range from the

relatively minor violations (e.g., reports submitted a week late) to major violations causing

adverse environmental effects, health problems, or interference or pass through at the City’s

wastewater treatment plant. Each instance of noncompliance is a violation and sound

enforcement policy would be to review each and respond appropriately. Selection of the

appropriate enforcement response will relate to whether the violation is major or minor and

other factors such as the duration of the violation, compliance history of the violator, good

faith of the violator, and the harm caused by the violation. For example, if a self-monitoring

report is late by a week, the City may not consider that a serious violation. In most cases, a

telephone call or notice of violation from the City requesting an explanation will bring the

problem to the attention of the IU’s management. Frequently, such a notification is sufficient

to correct the problem.


Isolated violations will usually be attributed to a relatively simple problem that can be easily

corrected. Although the tendency is to assume that minor violations are unimportant, the

persistence of minor violations could indicate a more serious problem and necessitate an

escalated enforcement response. More aggressive enforcement actions should normally be

taken against facilities that frequently exceed numerical pretreatment standards than those

that report isolated violations (unless the isolated violations are large and troublesome).

Informal meetings or a written notice of violation should seek specific explanations of the

causes of frequent violations. If inadequate operating practices are found to be the cause, the

City should seek specific commitments and deadlines to improve operating practices. If

additional treatment is required, an enforceable compliance schedule should be issued to the

industrial facility.

If the IU personnel appear to be attempting in good faith to comply with pretreatment

requirements, the City enforcement actions should be on a more cooperative level than if the

IU personnel do not appear to attempt to comply in good faith.

However, the City should be aware that the Clean Water Act requires extraordinary efforts to

comply with its requirements in a timely way. Good faith must be measured against this

standard. Congress clearly expresses the efforts that are expected:

“The act requires industry to take extraordinary efforts if the vital and

ambitious goals of the Congress are to be met. This means that business-as-

usual is not enough. Prompt, vigorous, and in many cases, expensive

pollution control measures must be initiated and completed as promptly as

possible. In assessing the good faith of a discharger, the discharger is to be

judged against these criteria. Moreover, it is an established principle, which

applies to this act, that administrative and judicial reviews are sought on the

discharger’s own time.” [Legislative History of the Clean Water Act, No. 95-14, Vol. 3,

p. 463.]

A facility that challenges a permit or applicable pretreatment standard and delays progress

toward compliance, the facility assumes the risk that the permit, contract, or standard will be

upheld on judicial review. If the facility begins aggressively to come into compliance only

after a decision is made adverse to its interests, it cannot be considered to have acted in good

faith. Likewise, if a facility follows business-as-usual procedures, it cannot be considered to

have acted in good faith.

IU noncompliance that results in interference with the publicly owned treatment works

(POTW) or causes pass-through of pollutants should be addressed through formal

enforcement action and penalties to ensure that adequate treatment and compliance is

achieved promptly. In some cases, injunctive measures will also be appropriate.

B. Descriptions of Enforcement Actions

1. Notice of Violation


A NOV (LMC §13.26.110.B) is official notice to the discharger that a violation

has occurred. A written NOV served upon an IU by Pretreatment Coordinator for

violations of the pretreatment ordinance is considered a formal enforcement

action. A verbal NOV is considered an informal enforcement action. A NOV

notifies the discharger of the specific sections of the City Codes and/or discharge

permit that are being violations and the basis of the evidence for determining

noncompliance. In addition, the NOV may request that discharger conduct self-

investigation into the cause and solutions to the noncompliance. In some cases,

additional testing is warranted and may be included in an NOV, whether formal

or informal. It is the preferred policy of the City that written formal NOVs be

issued for all violations of numerical limits and failure to meet monitoring and

reporting schedules. Informal NOVs should be used for minor noncompliance

such as late reports (only a few days late), incomplete reports, or omissions in

submittals that are considered to be minor infractions. (Refer to LMC

§13.26.110.A.)

2. Administrative Order

Administrative Orders are formal enforcement actions and never considered to be

informal. An Administrative Order is typically an escalated enforcement response

to unabated noncompliance following the issuance of several NOVs. However, if

warranted by the severity of the violation, an Administrative Order may be issued

without prior issuance of a Notice of Violation. The Administrative Order

follows a similar format as a written NOV and establishes the legal authority of

the City to issue the Administrative Order; the specific findings of

noncompliance and the potential enforcement actions available to the City should

an escalation of enforcement be necessary. In addition, the findings may provide

additional historical information related to the noncompliance. The

Administrative Order also establishes an Order requiring the discharger to take

specific actions within a specified time limit and to report the results of the order

within a specified time period. The actions ordered under an Administrative

Order should provide a logical path to compliance. The City shall not specify

specific treatment processes or service providers in an enforcement action but

rather require the discharger to investigate the nature of the violation and

appropriate options for resolving the noncompliance. Sometimes this takes the

form of requiring the discharger to hire qualified professional assistance in

studying the problem and identifying possible solutions. Administrative Orders

may also require the discharger to develop action plans to achieve compliance

which may include the purchase and installation of pretreatment equipment.

a. Consent Order

A Consent Order (LMC §13.26.110.B) uses a format similar to a NOV. Consent

Orders are issued when the appropriate solution to the noncompliance is known


and the discharger proposes a schedule of actions and a timeline for completing

the actions and reporting progress and completion. Under a consent order, the

City allows the discharger to continue the discharge, even if it is in violation of

the permit requirements, providing the discharge does not result in pass through

or interference, or pose a threat to life or health of the treatment plant/sewer

system works or the general public. The violations are not excused during the

period of the Consent Order, but the City reframes from escalation of

enforcement providing the discharger conforms to the schedule and returns to

compliance within the specified time period. In some cases, the City may

establish interim discharge limits for those pollutants determined to be in

noncompliance. These interim limits will only be in effect during the term of the

Consent Order. Consent Orders may also establish modified self-monitoring and

City monitoring requirements during the term of the Consent Order.

b. Compliance Order

A Compliance Order (LMC §13.26.110.D) uses a format similar to a NOV.

Compliance Orders are issued when the discharger does identify and develop

solutions to the noncompliance. In some cases, the discharger fails to take a

proactive approach to solving compliance issues and allows the noncompliance to

continue unabated. A Compliance Order is a mandatory order originated and

issued by the City. It establishes a schedule of corrective actions that are intended

to bring the discharger into compliance. The Compliance Order establishes

milestone dates for completion of activities and reporting the status and

completion of the required activities. Compliance Orders often have monetary

penalties associated with a failure to attain a milestone date.

Interim discharge limits may be established during the term of the compliance

order. However, the City may retain the original discharge limitations and

continue to enforce violations of the limits during the term of the Compliance

Order. This may include the assessment of fines and penalties for additional

violations during the term of the compliance order. Compliance Orders may

require the discharger to halt or cease operations of certain production processes

within the permitted facility until the corrective actions are completed.

A Compliance Order is considered to be an escalation of enforcement from a

Consent Order or a NOV. However, the City may issue a Compliance Order

without issuing a NOV or a Consent Order. The issuance of a consent order does

not preclude the authority of the City to escalate enforcement by issuing a

Compliance Order to replace a Consent Order.

c. Cease & Desist Order

A Cease & Desist Order (LMC §13.26.110.E) is an escalated enforcement action

intended to effect an immediate response. It is different from an Emergency


Suspension, in that, the Cease & Desist Order must be issued by the Director of

Public Works or above and specifies the specific activities that must be halted

immediately. A Cease & Desist Order is not intended to order a discharger to

simply Cease & Desist noncompliance. The City must be specific and the order

must be intended for immediate actions. A Cease & Desist Order is usually

issued to halt one or more of the production processes within a facility due to the

adverse impact created by those specific production processes.

A Cease & Desist Order does not require that a condition or date be established

for a return to the activity ordered to be halted. The Cease & Desist Order should

provide a mechanism for the discharger to restart their operations when corrective

actions and preventative actions have been taken and the City has determined that

resumption of operations will not result in a violation of the discharge permit or

City Codes.

The City must be prepared to immediately escalate to more severe enforcement

actions should the discharger fail to comply with a Cease & Desist Order. A

failure to comply with a Cease & Desist Order should be enforced by a severance

of water service of other means to halt the entire discharge from the facility.

3. Show Cause Hearing

A Show Cause Hearing (LMC §13.26.110.C) is a formal enforcement action and

constitutes an escalation of enforcement. A Show Cause Hearing is a meeting

between representatives of the City and the Discharger to allow the discharger to

“show cause” why a proposed enforcement action should not be taken by the City

against the discharger. This is an official meeting and may be attended by the

City Attorney, Public Works Director, and City Manager. The discharger should

be represented by one or more of those persons declared to be an Authorized

Representative and in some cases by their attorney. The minutes of the meeting

should be kept by a qualified secretary or court recorder. The Show Cause

Hearing allows the discharger to present evidence supporting their position and

demonstrating their corrective and preventative actions to comply with the

ordinance and discharge permits. Show Cause Hearings are usually held prior to

the City taking enforcement actions that result in the assessment of administrative

fines; mandatory compliance orders; civil and/or criminal actions. The discharger

should be advised prior to the hearing of the seriousness of the meeting and the

possible outcomes of the meeting. The City is not obligated to make a decision at

the time of the Show Cause Hearing. Rather, the City should evaluate the

evidence presented and consider the evidence before making a final decision on

the planned enforcement actions. The City is not obligated to hold a Show Cause

Hearing and a failure to hold a Show Cause Hearing does not prevent the City

from taking any enforcement action granted under the City Codes.

5. Termination of Discharge


Termination of Discharge (LMC §13.26.110.H) is the revocation of an IU's

privilege to discharge industrial wastewater into the City's sewer system.

Termination may be accomplished by physical severance of the industry's

connection to the collection system; by issuance of an Administrative Order

which requires the IU to terminate its discharge; or by a court ruling. Section G of

this part discusses how and when to terminate an IU’s privilege to discharge.

Significant IUs are required to obtain and maintain a wastewater discharge permit

authorizing the discharge of process wastewater from their facility to the City

Sewer. Termination of that permit typically results in the shutdown of the

production process. However, if the discharger has sufficient storage capacity on-

site, they may be able to continue discharging and to transport the process

wastewater to an alternate disposal site and thus not discharging the process

wastewater into the City’s sewer system. Termination the Permit is not an

emergency action. It is an escalation of enforcement and typically follows

multiple enforcement actions for persistent violations of the permit and/or City

Codes. However, the City may terminate a permit as an initial enforcement action

based on the severity of the noncompliance. Typically, one or more Show Cause

Hearings will have been held prior to termination. Once a permit has been

terminated, the discharger must submit a new permit application and must

demonstrate the ability to attain 100% compliance before a new permit is issued.

A full start up plan that will allow the operation of the production process and

discharge testing may be required before the permit becomes effective. If the start

up fails to confirm compliance, the permit may become void immediately without

further enforcement actions taken by the City.

6. Administrative Fines

Administrative Fines (LMC §13.26.110.F) are punitive in nature and intended to

encourage compliance. Administrative Fines are not a cost recovery tool,

although they are often assessed at the same time as a cost recovery assessment.

Administrative Fines are intended to make compliance more economically

desirable than noncompliance. Section F of this part discusses the assessment of

administrative fines and how to determine the amount of the administrative fine.

The monetary penalties assessed by the City for violations of pretreatment

standards and requirements are not to exceed one thousand dollars ($1,000) per

violation per day. Unlike Civil and Criminal Penalties, Administrative Fines do

not require court intervention. The discharger may elect to pay the fines, or they

may appeal the fine. The appeal process is conducted through the City staff,

starting with the Director of Public Works, then the City Manager, and then to the

Council. The City Attorney should be involved during the original assessment of

the administrative fines and should be present during all appeal hearings. If the

discharger expires all administrative appeals, they can then file their appeal with

the courts and the City will have to defend the City’s action with regards to the


administrative fine. In some cases, administrative fines may be established based

on the successful accomplishment of a compliance activity on, or before a

milestone completion date. In this case the administrative fine is assessed

following the failure of the discharger to comply with the consent, or compliance

order.

4. Emergency Suspensions

Emergency Suspension (LMC §13.26.110.G) of wastewater service and/or

industrial wastewater discharge permit may be initiated by the City when

necessary to stop an actual, or threatened, discharge which presents, or may

present, an imminent endangerment to the health or welfare of persons, to the

environment, causes interference to the POTW, or causes the City to violate any

condition of its National Pollutant Discharge Elimination System (NPDES)

permit. Emergency Suspensions may be implemented verbally by notification to

the immediate shift manager/supervisor with written Emergency Suspension

Notification to follow within 24 hours of the verbal notification. Emergency

Suspension of sewer services means that the discharger must immediately halt all

production unless they have sufficient storage capacity to prevent a discharge

from the permitted facility. The City must be very certain of the situation and

discharge conditions before ordering an Emergency Suspension, because the City

may be held liable for losses incurred by the discharger as a result of the

suspension. The City needs to gather all evidence and make certain the evidence

is properly documented to be legally defensible evidence.

7. Civil Penalties

Civil Penalties (LMC §13.26.120.B) are the formal process of filing lawsuits

against IUs to secure court ordered action to correct violations and to secure

penalties for violations including recovery of costs to the City as a result of

noncompliance by the discharger. The discharger will not be fined more than one

thousand dollars ($1,000.00) for each offense. This process may include

injunctive relief (LMC §13.26.120.A) to protect the wastewater treatment plant

while the civil courts complete the case. The pretreatment staff should collect and

document evidence. Civil actions are initiated by the City Manager and the City

Attorney, with the approval of the City Council and Mayor.

8. Criminal Penalties

Criminal Penalties (LMC §13.26.120.C) are the formal process of charging

individuals and/or organizations with violations of ordinance provisions that are

punishable, upon conviction, by fines and/or imprisonment. The City of Lathrop

Sewer Use Ordinance provides that anyone violating a provision of this

ordinance, shall be deemed guilty of a misdemeanor, and upon conviction shall

be punished by a fine not to exceed one thousand dollars ($1,000.00) a day for


each violation and/or imprisonment not to exceed six (6) months for each

offense. The pretreatment staff is tasked with the gathering and documentation of

evidence. The City Manager and the City Attorney initiate criminal actions with

the approval of the City Council and Mayor.

9. Supplemental Enforcement Responses

Additional enforcement responses are provided in Section 13.26.130 of the ordinance:

Response Reference

Performance Bonds Requirement §13.26.130.A

Liability Insurance Requirement §13.26.130.B

Water Supply Severance §13.26.130.C

Additionally, the City has sufficient flexibility in establishing permit conditions and

requirements to utilize other supplemental responses such as short-term permits. The

pretreatment staff is tasked with the gathering and documentation of evidence. The

Public Works Director and City Manager establish the criteria for performance bonds

and/or liability insurance to be provided by the discharger as a requirement of a

compliance order.

Water Supply Severance

Water Supply Severance (LMC §13.26.130.C) is an easily implemented supplemental

enforcement action, unless the discharger receives water from a well or other

jurisdiction. If the discharger receives water from the City’s water system, the City may

issue a disconnect order to the water department to sever the water supply to the

facility. This action is usually not taken as an emergency enforcement action. It usually

results in the halting of the production process but often follows multiple enforcement

actions, escalating the enforcement to this action as an ultimate enforcement action.

Unlike an Emergency Suspension, Waste Supply Severance is usually well documented

over a period of time, and often follows multiple Show Cause Hearings. It is usually

very difficult for the discharger to obtain recovery of financial and/or property damages

from the courts due to the escalation of enforcement taken by the City. The City may

sever the water supply as an initial enforcement action based on the severity of the

noncompliance. As an initial enforcement action, the City will need to provide good

evidence to support this enforcement action as an initial enforcement action. Once the

water supply has been severed, the discharger must re-apply for the wastewater

discharge permit and demonstrate the ability to obtain 100% compliance upon

resumption of discharge.

C. Enforcement Order Format

It is important to establish the seriousness of the enforcement order and not to leave any


doubt in the permit holder’s mind that the enforcement order is an official document. All

enforcement orders should be written on City Letterhead and should follow a set format.

Enforcement orders should not take on the format of a business letter. The example orders

provided in Appendix A are examples of official document formats with the elements needed

in the different enforcement orders available under the City ordinance. An enforcement order

should accomplish the following:

1. Identify the entity against whom the enforcement action is taken.

2. Establish the Legal Authority of the City to take the enforcement action.

3. Establish the evidence of violations, also termed “Findings.”

4. Clearly notify the discharger that they are in violation of the permit and/or ordinance.

5. Clearly issue a Direct Order to the discharger specifying the actions necessary to comply

with the order and to return the permitted facility to compliance. Specific milestone

dates should be established and specific reports and report due dates should also be

established. These dates should be established using calendar dates and not a

specified number of days from the issue date of the order. This will eliminate

confusion over the exact date the reports or activities are due.

6. The enforcement document must be signed by the City’s authorized agent with appropriate

authority for the type of enforcement action taken.

7. The date the Order is signed must also be clearly identified.

D. Procedures

1. The enforcement personnel identified in ERP are responsible for determining that a

violation has occurred and what type of enforcement response is required. The

enforcement personnel identified in the ERP should be trained in the implementation

and goals of the pretreatment ordinance and the contents of industrial wastewater

discharge permits. When a discharger is determined to be in noncompliance, the

persons identified in the ERP should review the evidence and the ERP and determine

the appropriate enforcement action to be taken. The basis for taking an enforcement

action inconsistent with the ERP should be well documented before the action is taken.

Enforcement actions are usually reviewed by the State and/or EPA during routine

inspections. If a discharger fails to comply with the enforcement order, the City should

be able to demonstrate an escalation of enforcement consistent with the ERP.

2. The time frames for responses are as follows:

a. All violations should be identified and documented within five (5) days of receiving

compliance information.

b. Initial enforcement responses (involving contact with the IU and requesting

information on corrective or preventative action(s) should occur within fifteen

(15) days of violation detection.

c. Follow up actions for continuing or recurring violations should be taken within thirty


(30) days of the initial enforcement. For all continuing violations, the response

will include a compliance schedule.

d. Violations which threaten health, property or environmental quality are considered

emergencies and will receive immediate responses such as halting the discharge

or terminating service.

e. All violations meeting the criteria for significant noncompliance should be addressed

with an enforceable order within forty-five (45) days of significant

noncompliance.

3. All investigative records and monitoring schedules shall be considered CONFIDENTIAL

and shall be maintained as CONFIDENTIAL to the full extent of the Law. In the event

of any requests for the release of investigative records and/or monitoring schedules, a

written request shall be made to the City Attorney for release of such information.

E. Tracking Enforcement Related Situations

The City utilizes manual records and computer spreadsheet software to track IU compliance.

The City conducts monitoring and inspections at least annually at all significant industrial

users. The pretreatment coordinator should maintain a record of enforcement actions taken

and a summary of activities and milestone dates that are established in the enforcement order.

As the discharge meets or fails to meet the milestone dates, the pretreatment coordinator

should record the milestone completion dates.

F. Assessment of Administrative Fines

1. Purpose

Assessment of fines are among the most effective responses noncompliance because

they may be assessed at the City's discretion and the amount of the fines may be

determined on an individual basis. Fines are punitive in nature and are not related to a

specific cost born by the City. Instead, fines are to recapture the full or partial economic

benefit by the discharger as a result of the noncompliance, and to deter future

violations.

2. Legal Authority

Legal authority of Administrative Finds is established in Section 13.26.110.F of LMC.

The following is quoted from the ordinance.

1. When the City finds that a user has violated, or continues to violate, any provision of this

ordinance, a wastewater discharge permit or order issued hereunder, or any other pretreatment

standard or requirement, the City may fine such user in an amount not to exceed one thousand

(1,000) dollars. Such fines shall be assessed on a per violation, per day basis. In the case of


monthly or other long term average discharge limits, fines shall be assessed for each day during

the period of violation.

2. Unpaid charges, fines, and penalties shall, after 60 calendar days, be assessed an additional

penalty of twenty-five percent (25%) of the unpaid balance, and interest shall accrue thereafter

at a rate of one percent (1%) per month. A lien against the user’s property will be sought for

unpaid charges, fines, and penalties.

3. Users desiring to dispute such fines must file a written request for the City to reconsider the fine

along with full payment of the fine amount within thirty (30) days of being notified of the fine.

Where a request has merit, the City may convene a hearing on the matter. In the event the user’s

appeal is successful, the payment, together with any interest accruing thereto, shall be returned

to the user. The City may add the costs of preparing administrative enforcement actions, such as

notices and orders, to the fine.

4. Issuance of an administrative fine shall not be a bar against, or a prerequisite for, taking any

other action against the user.

3. When to Assess Administrative Fines

Administrative Fines are recommended as an escalated enforcement response,

particularly when NOVs or Administrative Orders have not prompted a return to

compliance. Whether administrative fines are appropriate responses to noncompliance

also depends greatly on the circumstances surrounding the violation. When using this

enforcement response, either singly or in conjunction with another response the City

should consider the following factors:

The type and severity of the violation

The number of violations cited

The duration of the noncompliance

The impact of the violation on the wastewater treatment plant and the

environment

Whether the violation threatened human health

Whether the industrial user derived any economic benefit or savings form the

noncompliance

The compliance history of the user

Whether the user is making good faith efforts to restore compliance

Other policy considerations normally involved in an enforcement decision

4. Determining the Amount of the Fine

The amount of the fine should be proportionate to the economic benefit enjoyed by the

discharger as a result of the noncompliance and the harm caused by the violation. Each

violation in the Enforcement Response Matrix (provided in Part II in this Plan) has a

fine or penalty category assigned to it. The categories are related to dollar amounts as

shown in the following table:


FINE OR PENALTY PLAN BASED ON CATEGORY OF SEVERITY

Category Fine or Penalty

0 $0

1 $100 to $500

2 $500 to $750

3 $750 to $1,000

4 Administrative and/or Civil penalties imposed within the range of

Category 3, plus all expenses reasonably incurred by the City as a direct

result of the violation, and the cost of litigation including attorney fees

and expert witness fees.

When it has been determined that a fine is appropriate, the fine assessed should reflect

the severity of the noncompliance. The Enforcement Response Matrix provides a guide

in determining the severity of the violation. Determining a fine amount which reflects

the violation's significance is extremely important. If a fine is too small, its deterrent

value is lost and the amount may be regarded by the discharger as a tax or nominal

charge to pollute. If the fine is too great, it is more likely to be contested and could

bankrupt the industry. In cases of extreme hardship, the City may consider reducing or

suspending the fine as part of a Consent Order or a Show Cause proceeding. In some

cases, the discharger may offer to carry out an alternative environmental activity that

would be of benefit to the community, in lieu of a monetary fine. This practice is

acceptable providing the discharger receives no financial benefit from the activity and

that the discharger invest an equivalent amount in direct expenses or in-kind donations.

For guidance on calculating fines based on the economic benefit of noncompliance, see

the Guidance Manual for Calculation of Economic Benefit of Noncompliance with

Pretreatment Standards, U.S. EPA, 1989.

5. Method of Assessing Administrative Fines

Once the violation is documented and an appropriate fine amount is determined, the

City shall notify the industrial user of the fine by issuance of an Administrative Order.

The Administrative Order shall specify the violation, the actions required to return to

compliance, and the amount of the fine assessed. The Administrative Order shall

specify the method of payment and the due date. Collection of the fine shall follow

established City policy for collection of fines and fees. In no case shall the payment of

the fine be submitted to the wastewater treatment plant.

G. Termination of Sewer Service

1. General Discussion

Termination of service is the revocation of a discharger’s privilege to discharge

industrial wastewater into the City's sewer system. Termination is an administrative

function and does not require a court ruling. Termination may be accomplished simply

by the discharger halting all discharges. In some cases, a discharge isolation valve may


be shut and locked, while in other cases, the discharger may be required to physically

disconnect the piping from their facility to the City sanitary sewer. In some cases, the

City may have to actually dig up the sewer tap and physically disconnect and plug the

discharge line. When terminating services, the City should not expect to recover the

costs associated with the work necessary to accomplish the disconnect. However, if the

discharger corrects the previous problems and applies for re-connection, the City may

wish to impose additional costs to make the connection to recover the costs associated

with the disconnect. Once sewer service has been terminated, the discharger must re-

apply for a new wastewater discharge permit, as if they were a new source and must

provide evidence that the facility discharge will be in full compliance upon

commencement of discharge. The City must be aware that terminating services will

usually result in forcing the industry to halt production and may result in closure of the

facility. In some cases, the discharger may be capable of capturing the discharge and

using an alternative disposal method. However, this is typically not the rule. The City

must carefully consider all of the legal and operational implications of termination

before using this enforcement response. It is recommended that a Show Cause Hearing

be held prior to termination of services. This will allow the discharger an opportunity to

present his case for not terminating the service. It will also provide an opportunity for

the City to determine if terminating services will pose a health or safety threat to the

general public.

2. Legal Authority

LMC §13.26.110.H “Termination of Discharge;” §13.26.110.G “Emergency

Suspensions;” and §13.26.130.C “Water Supply Severance” establishes the City’s legal

authority to terminate services to a discharger.

3. When to Terminate Service

Termination of service is an appropriate response to industries which have not

responded adequately to previous enforcement responses and when the City must act

immediately to halt or prevent a discharge which presents a threat to human health, the

environment or the City’s wastewater treatment plant. Termination of services is

usually the only appropriate response for failure of the discharge to comply with a

Cease and Desist Order. Unlike civil and criminal proceedings, termination of sewer

service is an administrative response which can be implemented directly by the City.

The decision to terminate service requires careful consideration of its legal and

procedural consequences. It is likely that forcing an industrial user to halt production

will damage the industry's economic position. Nonetheless, this drastic measure is

sometimes necessary to address emergency situations or industries resistant to previous

enforcement measures. Service termination is sometimes used as an initial response to

noncompliance which causes or threatens to cause an emergency situation. However, it

is more frequently used as an escalated response to persistent significant violations

when other enforcement responses have failed to bring the discharger into compliance.

Assuming other enforcement responses are unsuccessful, the types of violations


warranting termination of service are:

a. Unauthorized discharges which violate the POTW's NPDES Permit or which create

a dangerous situation threatening human health, the environment, or the treatment

plant.

b. Discharges that exceed local or categorical discharge limits and result in damage to

the environment

c. Slug loads causing interference, pass through, or damage to human health, the

environment, or the treatment plant

d. Failure of the industrial user to notify the City of effluent limit violations or slug

discharges which resulted in environmental or POTW damage

e. Complete failure of the industrial user to sample, monitor, or report as required by a

discharge permit and/or an Administrative Order.

f. Failure of the industrial user to install required pretreatment and/or monitoring

equipment per the condition of a discharge permit and/or an Administrative

Order

g. Major violation of a permit condition and/or Administrative Order accompanied by

evidence of negligence or intent.

H. Publication

The City shall publish annually, in a newspaper of general circulation that provides meaningful

public notice within the jurisdictions served by the POTW, a list of the Users which, at any time

during the previous twelve (12) months, were in Significant Noncompliance with applicable

pretreatment standards and requirements. LMC §13.26.090 establishes the City’s legal authority to

publish users in Significant Noncompliance. The term Significant Noncompliance is defined in LMC

§13.26.090.


APPENDIX A

SAMPLE ENFORCEMENT DOCUMENTS


IN THE MATTER OF SURCHARGES

<<COMPANY NAME>> [TREATMENT COST RECOVERY]

<<Auth Rep NAME>> Permit #<<permit number>>

<<ADDRESS>>

LEGAL AUTHORITY

Pursuant to the Lathrop City Codes, Chapter 13, Section 26, "Sewer Use Ordinance," the Lathrop

Pretreatment Coordinator shall evaluate and assess surcharge fees based on the cost of treatment of

pollutants discharged from <<COMPANY NAME>>in accordance with §13.26.150 “Pretreatment Fees,”

of the Sewer Use Ordinance and Wastewater Discharge Permit #<<permit number>>.

FINDINGS

The Lathrop Pretreatment Coordinator has reviewed the Self-Monitoring Report and has determined that

Pollutants discharged from <<COMPANY NAME>> during the month of <<MONTH & YEAR>> are in

excess of Domestic Loadage and therefore shall be SURCHARGED for additional treatment as detailed in

the attached Surcharge Distribution Calculation.

ORDER

THEREFORE, BASED ON THE ABOVE FINDINGS, <<COMPANY NAME>> IS HEREBY

ASSESSED A TOTAL of $<<AMOUNT>> for treatment of pollutants in excess of domestic loading.

SURCHARGES ARE DUE AND PAYABLE WITHIN 30 DAYS OF ASSESSMENT.

Please Make Check Payable to: The City of Lathrop

Mail to the Attention of: <<NAME OF CITY OFFICIAL, TITLE>>

Wastewater Treatment Surcharges

<<SUBMITTAL ADDRESS>>

Signed: _______________________________________________________ Date: <<DATE>>

<<PUBLIC WORKS DIRECTOR/TITLE>>

cc. <<NAME OF PWD>>, Public Works Director

Pretreatment File

City of Lathrop

Department of Public Works

Engineering Division

(209) 941-7430


IN THE MATTER OF NOTICE OF VIOLATION

<<COMPANY NAME>>


<<ADDRESS>>

LEGAL AUTHORITY

Pursuant to the Lathrop City Codes, Chapter 13, Section 26, "Sewer Use Ordinance," the Lathrop Director

of Public Works has issued Wastewater Discharge Permit #<<permit number>> to <<COMPANY

NAME>> in accordance with §13.26.050 “Wastewater Discharge Permits” of the Codes.

FINDINGS

The Lathrop Pretreatment Coordinator has reviewed the Self-Monitoring Report for the month of

<<MONTH & YEAR>> submitted by <<name of Authorized Representative of permit holder>>. It has

been determined that the following pollutants reported by <<COMPANY NAME>> are in violation of the

numerical limits as specified by permit #<<permit number>>. (Example Findings table)

Parameter Limit

Reported

Value

Violations

*Chronic *TRC

BOD Conc Max Daily (5/26/05) 3,000 mg/L

3,130 mg/L 1

BOD Loading Monthly Avg 540 lbs/day

657 lbs/day 1

Note: *Chronic Violations are simple numerical values greater than the Limit.

*TRC Violations are Violations based on Technical Review Criteria; [Re: Lathrop Sewer

Use Ordinance and/or Enforcement Response Guide]

NOTICE

THEREFORE, BASED ON THE ABOVE FINDING, <<COMPANY NAME>> IS HEREBY

NOTIFIED THAT it is in violation of the terms and conditions of discharge permit #<<permit

number>>.and City Code of Ordinance §13.26.

ORDER


ORDERED TO TAKE THE FOLLOWING ACTIONS:

1. ex: Evaluate the production for May 2005 to determine unusual operations that could have resulted in

the high BOD reported for that date.

2. ex: Report the results of the evaluation in the comments section of Monthly Self-Monitoring Report for

the month of July 2005.

Signed:_______________________________________________________ Date: <<DATE>>

<<PRETREATMENT COORDINATOR NAME/TITLE>>

cc. <<NAME OF PWD>>,Public Works Director

Pretreatment File

RR # <<Return Receipt Number from Certified Mail>>

City of Lathrop



(209) 941-7430


IN THE MATTER OF CEASE AND DESIST ORDER

<<COMPANY NAME>>


<<ADDRESS>>

LEGAL AUTHORITY



NAME>> in accordance with §13.26.050 “Wastewater Discharge Permits” of the Codes.

FINDINGS

1. <<COMPANY NAME>>discharges process wastewater containing pollutants into the Lathrop sanitary

sewer system.

2. <<COMPANY NAME>> is a "significant industrial user" as defined by §§13.26.010.E. of the City

Codes.

3. <<COMPANY NAME>> was issued a wastewater discharge permit on <<issued date>> which contains

prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the

City sanitary sewer.

4. Pursuant to the ordinance and the above referenced permit, data is routinely collected or submitted on

the compliance status of <<COMPANY NAME>>.

5. This data shows that <<COMPANY NAME>> has violated the Sewer Use Ordinance in the following

manner:

a. Continuous violations of permit limits for <<identify parameter>> in each sample collected

between <<beginning date>> and <<ending date>>.

b. Failure to comply with an administrative compliance order requiring the installation of a

pretreatment system and the achievement of compliance with its permit limits by <<milestone

date>>.

c. Failure to appear at a show cause hearing pursuant to an order requiring said attendance.

City of Lathrop



(209) 941-7430


ORDER

Therefore, based on the above findings <<COMPANY NAME>> is hereby ordered to:

1. Within 24 hours of receiving this order, cease all non-domestic discharges into the City's sanitary sewer.

Such discharges shall not recommence until such time as <<COMPANY NAME>> is able to

demonstrate that it will comply with its current permit limits.

2. Failure to comply with this order may subject <<COMPANY NAME>> to having its connection to the

sanitary sewer sealed by the City, and assessed the costs therefore.

3. Failure to comply with this order shall also constitute a further violation of the sewer use ordinance and

subject <<COMPANY NAME>> to civil or criminal penalties or such other enforcement as may

be appropriate.

4. This order, entered this ___ day of <<month, year>> shall be effective upon receipt by <<COMPANY

NAME>>.

Signed: _______________________________________________________ Date: <<DATE>>

<<DIRECTOR OF PUBLIC WORKS/TITLE>>


Pretreatment File



IN THE MATTER OF CONSENT ORDER

<<COMPANY NAME>>


<<ADDRESS>>

CONSENT ORDER

WHEREAS, The City of Lathrop Public Works Department pursuant to the powers, duties and

responsibilities vested in and imposed upon the department by provisions of the Lathrop City Codes,

Chapter 13, Section 26, "Sewer Use Ordinance," have conducted ongoing investigations of <<COMPANY

NAME>> and have determined that:

1. The City owns and operates a wastewater treatment plant which is adversely impacted by discharges

from industrial users, including <<COMPANY NAME>>, and has implemented a pretreatment

program to control such discharges.

2. <<COMPANY NAME>> has consistently violated the pollutant limits in its wastewater discharges

permit as forth in Exhibit I, attached hereto.

3. Therefore, to ensure that <<COMPANY NAME>> is brought into compliance with its permit limits at

the earliest possible date, IT IS HEREBY AGREED AND ORDERED, BETWEEN <<COMPANY

NAME>> AND THE DIRECTOR OF PUBLIC WORKS FOR THE CITY OF LATHROP, THAT

<<COMPANY NAME>> SHALL:

a. By <<MILESTONE DATE not to exceed 30 days>>, obtain the services of a licensed

professional engineer specializing in wastewater treatment for the purpose of designing a

pretreatment system which will bring <<COMPANY NAME>> into compliance with its

wastewater discharge permit.

b. By <<MILESTONE DATE not to exceed 30 days from previous milestone date>> submit to the

City Pretreatment Coordinator, an engineer’s report with the permit holders options for

treating their discharge to permit standards with estimated capital and operating costs for each

option.

c. By <<MILESTONE DATE not to exceed 30 days from previous milestone date>> submit a

statement of decision to the pretreatment coordinator declaring the treatment option selected

by <<COMPANY NAME>>.

d. By <<MILESTONE DATE not to exceed 30 days from previous milestone date>> submit an

action plan for the design of the treatment system, funding of the capital costs,

commencement of construction, completion of construction, and commencement of

operations. This plan should provide milestone dates and routine status report due dates for

the activities needed to design and build the treatment system.

e. <<COMPANY NAME>> shall pay $<<fine amount>> per day for each and everyday it fails to

comply with the schedule set out in items a-d above. The $<<fine amount>> per day penalty

shall be paid to the City of Lathrop through the Public Works Director within 5 days of

City of Lathrop



(209) 941-7430


assessment of the fine by the City.

4. In the event <<COMPANY NAME>> fails to comply with any of the deadlines set forth,

<<COMPANY NAME>> shall, within one (1) working day after expiration of the deadline, notify

the City in writing. This notice shall describe the reasons for <<COMPANY NAME>> failure to

comply, the additional amount of time needed to complete the remaining work, and the steps to be

taken to avoid future delays. This notification in no way excuses <<COMPANY NAME>> from

its responsibility to meet any later milestones required by this Consent Order.

5. Compliance with the terms and conditions of the Consent Order shall not be construed to relieve

<<COMPANY NAME>> of its obligation to comply with its wastewater discharge permit which

remains in full force and effect. The City reserves the right to seek any and all remedies available

to it under the City's Code of Ordinances for any violation cited by this order.

6. Violation of this Consent Order shall constitute a further violation of the City's Sewer Use Ordinance

and subjects <<COMPANY NAME>> to all penalties described within the enforcement authority

of the City pursuant to §13.26.110 thru 140 of the City Code.

7. Nothing in this Consent Order shall be construed to limit any authority of the City to issue any other

orders or take any other action which it deems necessary to protect the wastewater treatment plant,

the environment or the public health and safety.

SIGNATORIES

FOR (Permittee Name)___________________________________ Date____________

FOR THE CITY OF LATHROP____________________________ Date______________

<<Signature Authorized City Official Name/Title>>


Pretreatment File



IN THE MATTER OF SHOW CAUSE ORDER

<<COMPANY NAME>>


<<ADDRESS>>

LEGAL AUTHORITY



NAME>>.

FINDINGS

1. <<COMPANY NAME>> discharges process wastewater containing pollutants into the sanitary sewer

system of the City of Lathrop.

2. <<COMPANY NAME>> is a "significant industrial user" as defined by §13.26.010.E. of the City's

Sewer Use Ordinance.

3. <<COMPANY NAME>> was issued a wastewater discharge permit on (date) which contains

prohibitions, restrictions, and other limitations on the quality of the wastewater it discharges to the

sanitary sewer.

4. Pursuant to the ordinance and the above-referenced permit, data is routinely collected or submitted on


5. This data shows that <<COMPANY NAME>> has violated its wastewater discharge permit in the

following manner:

a. <<COMPANY NAME>> has violated its permit limits for (parameter(s) in each sample

collected between <<start date>>, and <<end date>> for a total of <number of violations>>

separate violations of the permit.

b. <<COMPANY NAME>> has failed to submit a periodic compliance report due <<date>>.

c. All of these violations satisfy the City's definition of significant noncompliance.

ORDER


ORDERED TO:

1. Appear at a meeting with the Director of Public Works to be held on <<date and time>> at City Hall in

the office of the Director of Public Works.

2. At this meeting, <<COMPANY NAME>> must demonstrate why the City should not pursue a judicial

enforcement action against <<COMPANY NAME>> at this time.

3. This meeting will be closed to the public.

4. Representatives of <<COMPANY NAME>> may be accompanied by legal counsel if they so choose.

City of Lathrop



(209) 941-7430


5. Failure to comply with this order shall also constitute a further violation of the Sewer Use Ordinance

and may subject <<COMPANY NAME>> to civil or criminal penalties or such other appropriate

enforcement response as may be appropriate.

6. This order, entered this _____th day of <<MONTH/YEAR>>, shall be effective upon receipt by

<<COMPANY NAME>>.

Signed ________________________________________________ Date:_______________



Pretreatment File



IN THE MATTER OF COMPLIANCE ORDER

<<COMPANY NAME>>


<<ADDRESS>>

LEGAL AUTHORITY

The following findings are made and order issued pursuant to the authority vested in the City Codes,

Chapter 13, Section 26, "Sewer Use Ordinance." This order is based on findings of violation of the

conditions of wastewater discharge permit #<<permit number>> issued under §13.26.050 “Wastewater

Discharge Permits” of the Codes.

FINDINGS

1. <<COMPANY NAME>> discharges non-domestic wastewater containing pollutants into the sanitary

sewer system of the City of Lathrop (hereafter, "City").

2. <<COMPANY NAME>> is a "significant industrial user" as defined by §13.26.010.E. “Definitions” of

the City's Sewer Use Ordinance.

3. <<COMPANY NAME>> was issued a wastewater discharge permit on <<date issued>>, which

contains prohibitions, restrictions, and other limitations on the quality of the wastewater it

discharges to the sanitary sewer.

4. Pursuant to the ordinance and the above-referenced permit, data is routinely collected or submitted on


5. This data shows that <<COMPANY NAME>> has violated its wastewater discharge permit in the

following manner:

a. Violation of permit limit for <<parameter>> in each sample collected between <<start

Month/year>>, and <<end Month/year>>, for a total of <<number of violations>> separate

violations of the permit.

b. <<COMPANY NAME>> has failed to submit all periodic compliance reports due since report

due date>>.

c. All of these violations satisfy the City's definition of significant violation.

ORDER


ORDERED TO:

1. Within 180 days, install pretreatment technology which will adequately treat <<COMPANY NAME>>

wastewater to a level which will comply with its wastewater discharge permit.

2. Within 5 days, submit all periodic compliance reports due since <<report due date>>.

3. Within 15 days, pay to City of Lathrop, a fine of $<<amount of fine>> for the above-described

violations in accordance with §13.26.110.F. “Administrative Fines” of the City's Sewer Use

Ordinance.

4. Report, on a monthly basis, the wastewater quality and corresponding flow and production information

as described on page __ of the wastewater discharge permit for a period of one year form the

City of Lathrop



(209) 941-7430


effective date of this order.

5. All reports and notices required by this order shall be sent, in writing, to the following address:

Pretreatment Coordinator, City of Lathrop

16775 Howland Road

Lathrop, California 95330

6. This order does not constitute a waiver of the wastewater discharge permit which remains in full force

and effect. The City of Lathrop reserves the right to seek any and all remedies available to it under

the Sewer Use Ordinance #________ for any violation cited by this order.

7. Failure to comply with the requirements of this order shall constitute a further violation of the sewer use

ordinance and subject <<COMPANY NAME>> to civil or criminal penalties or such other

appropriate enforcement response as may be appropriate.

8. This order, entered this ____th day of <<Month/Year>>, shall be effective upon receipt by

<<COMPANY NAME>>.

Signed ________________________________________________ Date:_______________



Pretreatment File



SUSPENSION OF WASTEWATER SERVICE ORDER

Authorized Under §13.26.110.G. of the City Codes

Date of Notice ___________________

Business or Individual ____________________________________________

Address ___________________________________________________________

Person Contacted/Title ____________________________________________

City Pretreatment Ordinance Section Violation _____________________

Results of Analysis _______________________________________________

Due to the serious nature of your violation, the City of Lathrop is ordering you to immediately stop the

discharge of process wastewater, and to eliminate any further industrial discharging by

__________________ ___________.

<<Date>> <<Time>>

In the event of your failure to voluntarily comply with this suspension order, the City shall take such steps

as deemed necessary including, but not limited to, the immediate severance of your sewer connection, to

prevent or minimize damage to our POTW system or endangerment to any individuals.

____________________________________ Refused to sign ____ (initials)

Signature of person contacted

_____________________________________, ________________

Signature of City Representative Date


Pretreatment File


City of Lathrop



(209) 941-7430

City of Lathrop, California


Fat, Oil & Grease Source Control Program

Enforcement of Lathrop Municipal Code Chapter 13.26.160

(Sewer Use Ordinance #05-254)

City of Lathrop



Contents

I - INTRODUCTION ...................................................................................................................... 1

II - PURPOSE OF THE FOG ERP ................................................................................................. 1

III - FOG CONTROL PROGRAM OFFICIALS/STAFF ............................................................... 1

IV - ORDINANCE PROVISIONS ................................................................................................. 2

V - ENFORCEMENT RESPONSES.............................................................................................. 2

A. Levels of Response ........................................................................................................ 2

B. Response Actions ........................................................................................................... 2

C. Sequence of Actions ....................................................................................................... 4

VI - ADMINSTRATIVE FINES .................................................................................................... 4

VII - COST RECOVERY ............................................................................................................... 4

VIII - TERMINATION OF WATER SERVICES .......................................................................... 5

IX - NOTIFICATION OF HEALTH DEPARTMENT .................................................................. 5

X - SAMPLE DOCUMENTS ......................................................................................................... 5

1

City of Lathrop



I - INTRODUCTION

The City of Lathrop adopted Ordinance #05-254 amending Chapter 13.26.160 of the Lathrop

Municipal Code (LMC). This ordinance established General Sewer Use Regulations

including the adoption of Fat, Oil, and Grease (FOG) Control Regulations applicable to Food

Service Establishments (FSEs).

Under this code the City has the authority to enter FSEs to conduct inspections and sampling

as required to confirm compliance to the City Codes. This code also establishes mandatory

maintenance of grease interceptors and the City’s authority to take appropriate enforcement

actions for failure to comply with the codes.

The Director of Public Works is responsible for the implementation and enforcement of this

ordinance. Certain functions required to implement the ordinance are delegated to various

staff and contract services by the Director of Public Works. This Enforcement Response Plan

constitutes the policies and procedures that will be used to enforce the City’s fat, oil and

grease ordinance under the authority of the Public Works Director.

The FOG Enforcement Response Plan is directed at the enforcement of the FOG regulations.

A separate Enforcement Response Plan has been established for the enforcement of the

industrial user regulation contained in the City Code.

II - PURPOSE OF THE FOG ERP

The purpose of the FOG Enforcement Response Plan is to provide uniform and consistent

enforcement of the City Codes using a variety of enforcement options that are available to the

City. This will allow the City to be flexible in their response to a violation and to provide

guidance in responses to assure the response is appropriate to the type of violation that

occurred.

III - FOG CONTROL PROGRAM OFFICIALS/STAFF

Director of Public Works - 209-941-7430

City Attorney - 209-941-7235

Veolia Water-NA Project Manager - 209-858-1645

City Pretreatment Coordinator - 209-858-1645

2

IV - ORDINANCE PROVISIONS

Ordinance Provision

13.26.160.A. Findings (Purpose)

13.26.160.B. Applicability

13.26.160.C. Definitions

13.26.160.D.1. Grease Interceptor/Trap Required

13.26.160.D.2. Existing Facilities

13.26.160.D.3. New Facilities or New Interceptor Installations

13.26.160.E.1. Maintenance of Grease Interceptor/Traps Required

13.26.160.E.2. Routine Maintenance Schedules

13.26.160.E.3. Record Keeping Requirements

13.26.160.E.4. Record Retention Requirements

13.26.160.F. Disposal of Interceptor/Trap Wastes

13.26.160.G. Collection, Storage, and Disposal of Waste Grease and Solids

13.26.160.H. Clean up of Spilled Grease and Oil

13.26.160.I. Use of Chemicals and Other Additives

13.26.160.J. Right of Access

13.26.160.K. Enforcement

13.26.160.K.1. Mandatory Interceptor/Trap Service

13.26.160.K.2. Mandatory Interceptor/Trap Service Schedule

13.26.160.K.3. Cost Recovery

13.26.160.K.4. Administrative Fines

13.26.160.K.5. Emergency Suspensions

V - ENFORCEMENT RESPONSES

A. Levels of Response

There are three possible levels of response to all violations available to the City:

Level 1 – Education and Training

Level 2 – Informal Enforcement

Level 3 – Formal Enforcement

B. Response Actions

Level 1 responses are the most common enforcement tool used in the FOG program.

A Level 1 response typically includes providing the user with a copy of the

ordinance, and a summary of the FOG Program requirements, information on best

management practices, and a brief discussion on the proper maintenance of the

interceptor or trap used by the facility (a copy of the City’s FSE best management

practice hand-out is included in Part X of this ERP). It also includes an inspection

and the gathering of general and specific information about the facility, the

3

owner/operators, the interceptors installed at the facility, and the current maintenance

practices. A Level 1 response is intended to inform the user of their responsibilities,

provide them with sufficient information to develop an effect maintenance program,

and then to allow them time to attain compliance. A Level 1 response will always be

followed up with inspections following an adequate amount of time for the user to

develop and implement their maintenance plan.

Level 1 – Responses

• Educate, Inform, Train

• Data Gathering

• Inspection

Level 2 responses are considered an escalation of enforcement. A Level 2 response is

an appropriate response for the failure of the user to develop an appropriate

maintenance plan (schedule), especially following a Level 1 action. A Level 2

response is typically a mandatory pumping order, requiring the user to hire a grease

trap cleaning service to pump the interceptor and clean it within a specified time

frame and to submit copies of the cleaning service pumping/transport manifest to

document the service was performed. A Level 2 response may include a mandatory

requirement that a licensed plumber be hired to inspect the grease interceptor when

the cleaning service pumps down the interceptor to confirm the interceptor is

properly installed and that none of the fittings and fixtures are damaged, broken, or

missing. Level 2 responses require that mandatory actions be taken within a specified

time period and that the results of the action be reported to the FOG Control Program

Manager within a specified time period. Level 2 responses do not include the

assessment fines or penalties. Level 2 responses are intended to mandate a corrective

action to be taken by the user, at the user’s expense.


• Mandatory Cleaning of Interceptor

• Mandatory Inspection of Interceptor by Licensed Plumber

• Mandatory Repair of Damaged Interceptor

• Mandatory Reporting

Level 3 responses are considered an escalation of enforcement. A Level 3 response is

an appropriate response for the user who refuses to conform to the ordinance and

avoids or ignores Level 1 and Level 2 enforcement actions. A Level 3 response will

typically include the mandatory actions that would be taken under a Level 2 response

with the addition of an administrative fine and/or prescribe additional penalties if the

user fails to perform the mandatory requirements. A Level 3 response may include a

mandatory interceptor cleaning and reporting requirement that must be followed on a

permanent (on-going) basis.


• Mandatory On-Going Interceptor Cleaning and Reporting Schedule

4

(example: monthly, quarterly, semi-annual)

• Mandatory Reconfiguration of plumbing to interceptor by Licensed

Plumber (interceptor installed backwards, dishwasher

discharge redirected from interceptor, removal of food

grinder (garbage disposal), etc.

• Mandatory replacement of undersized interceptor with properly sized

interceptor.

• Mandatory installation of interceptor in the discharge of an Existing

Food Service Facility.

• Assessment of Administrative Fines.

• Halt discharge to City Sewer System.

• Civil Legal Action.

• Criminal Legal Action.

C. Sequence of Actions

The City is not bound to taking the Level of Response in any sequential order. The City may

use a combination of the actions recommended in different response levels. The City may

take a Level 2 or a Level 3 as their first enforcement response based on the severity and the

impact the violation had on the City sewer system and the community health and safety.

VI - ADMINSTRATIVE FINES

It is not the intent of the FOG ERP to discuss how to assess and collect administrative fines.

Other sections of the City Codes provide authority and protocols for the City to assess fines.

In addition, the City’s Sewer Use Ordinance ERP provides a discussion of assessing

administrative fines for the City’s pretreatment program. A brief discussion of when to assess

an administrative fine under the FOG control program is provided herein.

Administrative fines are meant to be punitive in nature and are not related to cost recovery

for expenses accrued by the City to abate the results of the non-compliance to the ordinances.

Fines are not intended to replace enforcement actions that are directed at correcting the

problem and bringing the user into compliance with the ordinances. The City must not assess

a fine in excess of $1,000 per day per violation as established by State law. The assessment

of fines is usually reserved for those users who demonstrate a persistent pattern of non-

compliance. The City should carefully consider the use of a fine and its ability to make non-

compliance to the ordinance less profitable for the offender.

VII - COST RECOVERY

The City may assess cost recovery fees to users whose non-compliance resulted in damages

or restrictions to the City systems that resulted in expenses to the City above and beyond the

normal operational and maintenance costs associated with the system. As this applies to the

FOG control program there are two specific cases that the City may wish to assess cost

5

recovery fees to a user regulated under this ordinance.

(1) Build up of FOG in the collection line as a result of improper maintenance of a grease

interceptor that requires the City to clean that section of line more often than once

every 2 years.

(2) Cost related to the clean up of a Sanitary Sewer Overflow caused by the blockage to flow

in the sanitary sewer line caused by improper maintenance of the grease interceptor

servicing one or more users discharging to the blocked sewer line.

Cost recovery may be assessed on a one-time basis, which would be appropriate for a single

sanitary sewer overflow event; or as an on-going surcharge on users of a specific line that

services one or more FOG user. Cost recovery is not intended to be an enforcement tool, but

a means to recovering costs due to negligence on the part of a user, who has received a

Level 1 enforcement response in the past.

VIII - TERMINATION OF WATER SERVICES

The City provides both sewer and water to the food service establishments. Therefore, the

City may terminate water service as an ultimate enforcement tool. If a user fails to comply

with the City ordinance, and is persistently in non-compliance even though the City has taken

enforcement actions at the Level 1, 2 and 3, then the City may terminate water services. This

is not an action to be taken lightly for it will mean that the business can no longer operate in

the City.

Restoration of water service should only be granted upon documentation that the non-

compliant issues have been resolved and that consistent compliance may be expected in the

future. In addition, all previous enforcement actions and administrative fines and cost

recovery assessments must be paid prior to restoration of service.

IX - NOTIFICATION OF HEALTH DEPARTMENT

When in opinion of the City, a user grease interceptor is backing up causing a potential

health hazard, the City is required to notify the County Health Department of the food service

facility and the situation with the potential health risk.

X - SAMPLE DOCUMENTS

The following documents are samples of documents that are used in the enforcement of the

City FOG Control Ordinance.

1

Report Due Date:

Please complete this form and submit it, along with a copy of the latest pumping transport manifest for your facility.

Submittal of this report is required by the City. Failure to submit the completed and signed report is considered a

violation of the City Codes and subject to enforcement. Submit this report to: Lathrop FOG Control Program, 18800

Christopher Way, Lathrop, CA 95330. If you have questions concerning this matter please contact the Lathrop

Pretreatment Coordinator at 209-858-1645.

Business Name: Business Owner:

Business Location: Business Owner’s Address & Phone#

Mailing Address: Manager’s Name:

Local Business Phone #

Please circle the correct response for all “YES” or “NO” questions.

1. Business Facility sewer is connected to the City Sewer System? YES NO

2. Grease Trap Installed? YES NO

3. Provide the Volume of the Grease Trap measured in gallons:

4. Chemicals, Bacteria, or other Grease Trap Additives are added to the Grease Trap? YES NO

5. Food Grinders or Garbage Disposal is installed and discharges to the Grease Trap? YES NO

6. Automatic Dishwasher is installed and discharges to the Grease Trap? YES NO

7. Provide the Following Information on the Last 4 times the Grease Trap was Pumped:

Pumping

Date

Volume

Pumped

(gallons)

Pumping

Service

Name

Pumping

Service State

Registration

No.

Disposal

Site

Name

Disposal

Site State

Registration

No.

"I Certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system

designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person(s) who manage

the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, are

true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines. All

records used to compile this report are on file and available for inspection on request." Manager’s Name: (print or type) Manager’s Signature: Date Signed:

This report must be signed by a manager of the business and all additional requested information attached to be considered COMPLETE by the City.

Food Service Grease Trap

Maintenance Report

2

Business Name: Manager’s Name:

Business Location: Local Business Phone #

All businesses operating food service grease traps are required to properly maintain their grease traps in good working order

to prevent the release of excess fat, oil, and grease to the City’s sewer system. The operator is required to establish and

implement a routine pumping schedule with a service that collects, handles, transports, and disposes of the wastes in

accordance with State laws.

This Mandatory Service Order is issued because excessive buildups of fat, oil and grease (FOG) in the sewer

collection system servicing your facility has been found by City Maintenance Crews; and your business is suspected to be

the source of this fat, oil and grease. The City is requiring your business to remove all collected floating grease, all

wastewater, and all settled solids from your grease trap; and to inspect the interior of the grease trap for damage. All

damages found in the grease trap must be properly repaired before placing the grease trap back into service. The removed

FOG, wastewater, and solids must be properly manifested for transport and disposal. To verify that this work has been

accomplished in the prescribed time period, the City is requiring you to submit a copy of the manifest to the City’s

Pretreatment Coordinator. In addition, the City may have requested you to complete and submit a “Food Service Grease

Trap Maintenance Report.” This requested reporting is also mandatory.

Failure to comply with this order shall be considered a violation of the City Codes and subject to enforcement

actions. The City may also seek cost recovery from you for expenses incurred by the City to remove the excess FOG from

the City’s Sewer Lines.

If you have any questions concerning this matter, please feel free to contact the City’s Pretreatment Coordinator, at

209-858-1645.

Submit a copy of this order and the service manifest to the following:

Lathrop FOG Control Program, 18800 Christopher Way, Lathrop, CA 95330

Required Actions and Time Allowed for Completion of Tasks

1. Pump Grease Trap (completely) using a qualified Grease Trap

Maintenance Service. This task must be completed within the

following time period:

Hours,

Days

Weeks

2. Submit copy of Grease Trap Waste Transport Manifest to City

Pretreatment Coordinator, 18800 Christopher Way, Lathrop, CA

95330. Submittal Due:

15 days following

grease trap pumping

3. Complete the “Food Service Grease Trap Maintenance Report” and

submit to City Pretreatment Coordinator, 18800 Christopher Way,

Lathrop, CA 95330. Submittal Due:

15 days following

grease trap pumping.

4. Other Required Actions:

The City will consider any requests from the business for extension of due dates or modifications to the requested actions.

However, the business may be held responsible for any and all damages and costs incurred by the City as a result of the

business’s failure to take prompt corrective and preventative actions.

Order Issued by: (print or type) Signature: Date Issued:


Mandatory Service Order

3

Establishment

Name:____________________________________________________

Location:__________________________________________________

Mailing Address:____________________________________________

City: __________________ State:______, Zip Code:______________

Business Phone No.

Owner/Manager:

If your establishment does NOT have a grease trap or grease interceptor installed, mark this

box, and skip to the bottom and sign and date the questionnaire.

IDENTIFY MAINTENANCE SERVICE COMPANY: Identify the service company that pumps the grease

trap/interceptor at your establishment.

Company

Name

Mailing Address CA Transporter

Registration No.

IDENTIFY DISPOSAL SITE: Identify the facility that receives the grease trap/interceptor wastes for final disposal.

Company

Name

Mailing Address CA Treatment or Disposal Site

Registration No.

How often and how many gallons are typically pumped from the trap/interceptor?

How many gallons can the trap/interceptor hold?

YES NO Are Chemicals, Enzymes, Bacteria, or other grease trap/interceptor

additives used at your establishment?

YES NO Is there a food grinder in use at your establishment?

YES NO Are there drain screens in use at your establishment?

Name: (print):______________________________Date:__________ Signature:______________________

Mail To: Lathrop FOG Control Program

18800 Christopher Way

Lathrop, CA 95330

4

Food Service Establishment

Notification of FOG Control Ordinance Requirements

In order to provide for the public health and welfare, and to comply with the laws and regulations of

the State of California, the City of Lathrop adopted City Ordinance #05-254 adding Chapter 13.26 to

the Lathrop Municipal Code. Section 13.26.160 provides for the control of Fat, Oil and Grease

(FOG) discharged from food service establishments, such as restaurants and cafeterias. The intent of

these regulations is to prevent the build up of grease causing sewer backups and overflows to the

streets.

Your cooperation in the implementation of this ordinance is appreciated by the City. Wastewater

inspectors will be visiting all food service establishments in the next few weeks to provide assistance

in implementing the ordinance.

A copy of Section 13.26.160 of Ordinance No. 05-254, a summary of the Ordinance requirements,

and a list of suggested best management practices (BMPs) are enclosed.

Please take the time to review the enclosed information and complete the Food Service

Establishment Survey. Please mail the completed survey to the following address within 15 days:

Lathrop FOG Control Program


Lathrop, CA 95330

If you have questions, please feel free to contact the undersigned at (209) 858-1645.

FOG Control Program Manager

Establishment

Name:____________________________________________________

Location:__________________________________________________

Mailing Address:____________________________________________

City: __________________ State:______, Zip Code:______________

Business Phone No.

Owner/Manager:

If your establishment does NOT have a grease trap or grease interceptor installed, mark this

box, and skip to the bottom and sign and date the questionnaire.

IDENTIFY MAINTENANCE SERVICE COMPANY: Identify the service company that pumps the grease

trap/interceptor at your establishment.

Company

Name

Mailing Address CA Transporter

Registration No.

IDENTIFY DISPOSAL SITE: Identify the facility that receives the grease trap/interceptor wastes for final disposal.

Company

Name

Mailing Address CA Treatment or Disposal Site

Registration No.

How often and how many gallons are typically pumped from the trap/interceptor?

How many gallons can the trap/interceptor hold?

YES NO Are Chemicals, Enzymes, Bacteria, or other grease trap/interceptor

additives used at your establishment?

YES NO Is there a food grinder in use at your establishment?

YES NO Are there drain screens in use at your establishment?

Name: (print):______________________________Date:__________ Signature:______________________

Mail To: Lathrop FOG Control Program


Lathrop, CA 95330

Food Service Establishment

BEST MANAGEMENT PRACTICES

All food service establishments are encouraged to implement the following best management

practices:

• Installation of Drain Screens. Drain screens must be installed on all

drainage pipes in food preparation areas. Drain Screen cleanings

should be disposed of directly into the trash or garbage and not

in the sinks or drains.

• Segregation and Collection of Waste Cooking Oil. All waste cooking

oil must be collected and stored properly in recycling receptacles

such as barrels or drums. Such recycling receptacles must be

maintained properly to ensure that they do not leak. Food service

establishments must use licensed waste haulers and licensed

recycling facilities to dispose of waste cooking oil.

• Disposal of Food Waste. All food waste must be disposed of directly

into the trash or garbage, and not in sinks.

• Kitchen Signage. Best management and waste minimization practices

must be posted conspicuously in the food preparation and

dishwashing areas at all times.

• Food Grinders. Food grinders should not discharge to the grease trap.

• Odors. Grease trap devices must be installed and maintained, as

necessary, so as to prevent odors, cross-contamination, sewer

back-ups or Sanitary Sewer Overflows.

• Containers. Grease rendering containers must be installed and properly

maintained.


Inspection Report

Inspection Date:

Inspector(s)

Business Name: Business Owner:

Business Location: Business Owner’s Address & Phone#

Mailing Address: Manager’s Name:

Local Business Phone #

1. Frequency of Interceptor Service?

2. Interceptor Capacity (gallons)?

3. Name/Address of Service Company

4. Name and Rate of Addition of Interceptor Additives:

5. Visual Observations of Interceptor:

6. Food Grinders or Garbage Disposal is installed and discharges to the Grease

Trap? YES NO

7. Automatic Dishwasher is installed and discharges to the Grease Trap? YES NO

8. Best Management Practices implemented? YES NO

9. Provide the Following Information on the Last 3 times the Grease Interceptor was Pumped:

Pumping

Date

Volume

Pumped

(gallons)

Pumping

Service

Name

Pumping

Service

State

Registration

No.

Disposal

Site

Name

Disposal

Site

State

Registration

No.

10. List all Deficiencies:

11. List all Recommendations or Required Actions as a result of this inspection:

392793-2

INTERJURISDICTIONAL PRETREATMENT AGREEMENT

BETWEEN

THE CITY OF MANTECA

AND

THE CITY OF LATHROP

This Agreement is entered into this _______ day of_____________________________ 2005,

between the City of Manteca, hereinafter called “Manteca” and the City of Lathrop, hereinafter

called “Lathrop”.

RECITALS

1. Whereas, Manteca owns and operates a wastewater treatment system.

2. Whereas, Lathrop currently utilizes this wastewater treatment system pursuant to the

Service Agreement (Agreement A765) between Manteca and Lathrop dated March 5,

1984. Such use is called, for purposes of this Agreement, “use of the WQCF system”.

3. Whereas, Lathrop additionally owns and operates a second wastewater system, called, for

purposes of this Agreement, the “WRP System”.

4. Whereas, Facilities located in Lathrop currently contribute wastewater to the WQCF

system, which includes industrial waste. These facilities are hereinafter referred to as

industrial dischargers.

5. Whereas, Manteca must develop and implement an industrial pretreatment program to

control industrial dischargers of its wastewater treatment system pursuant to conditions

contained in its waste discharge permit (NPDES Permit No. CAOO8 1558 issued by the

EPA), and the pretreatment requirements set out in 40 CFR Part 403 and Division 7 of

the California Water Code.

6. Whereas, Lathrop desires to continue to utilize the WQCF system and recognize its

industrial waste control obligations under 40 CFR 403, Division 7 of the California

Water Code, and Agreement A765. In Agreement A765, Lathrop agreed to adopt and

maintain a waste ordinance that is uniform and consistent with the Manteca waste

ordinance so that the industrial dischargers to the WQCF system within Lathrop’ s

boundaries shall be subject to the necessary pretreatment controls. With this

interjurisdictional agreement, Manteca is authorized to implement and enforce that waste

ordinance within Lathrop’s boundaries, with respect to those industrial dischargers whose

waste flows to the WQCF system.

392793-2

AGREEMENT

1. Lathrop shall adopt a waste ordinance that is at least as stringent as to the waste

ordinance adopted by Manteca. Lathrop shall forward to Manteca for review a draft of its

proposed waste ordinance within (30) days of the date of this agreement. Lathrop shall

adopt its waste ordinance within (30) days of receiving approval from Manteca of its

content.

2. Whenever Manteca revises its waste ordinance, it shall forward a copy of the revisions to

Lathrop. Lathrop shall adopt similar revisions to its waste ordinance. Lathrop shall

forward to Manteca for review its proposed revision within (30) days of receipt of the

Manteca revisions. Lathrop shall adopt its revisions within (30) days of receiving

approval from Manteca of the content thereof.

3. Lathrop shall adopt pollutant specific local limits which include the same pollutant

parameters and limits that are as stringent as the local limits enacted by Manteca within

(30) days of the date of this agreement. If Manteca makes any revision or additions to its

local limits, Manteca shall forward to Lathrop a copy of such revisions within 10 days of

enactment thereof. Lathrop shall adopt any such revisions or additions within (30) days

of receipt thereof

4. Lathrop designates Manteca as the agent of Lathrop for the purposes of implementation

and enforcement of Lathrop’ s waste ordinance against industrial dischargers to the

WQCF system located in Lathrop. Manteca may take any action under Lathrop’s waste

ordinance that could have been taken by Lathrop, including the enforcement of the

ordinance in courts of law.

Manteca, on behalf of and as agent for Lathrop, shall perform technical and

administrative duties necessary to implement and enforce Lathrop’s waste ordinance.

Manteca shall: (1.) issue permits to all industrial dischargers to the WQCF system

required to obtain a permit; (2.) conduct inspections, sampling, and analysis; (3.) take all

appropriate enforcement action outlined in Manteca’ s enforcement response plan and

provided for in Lathrop’s waste ordinance; and (4.) perform other technical and

administrative duties required by Federal and State law or NPDES permit. In addition,

Manteca may, as agent of Lathrop, take emergency action to stop or prevent any

discharge to the WQCF system for an industrial user which presents or may present an

imminent danger to the health or welfare of humans, which reasonably appears to

threaten the environment, or which threatens to cause interference, pass through, or

sludge contamination.

6. Manteca shall maintain an industrial user inventory of permitted and non-permitted

industrial and commercial facilities discharging to the WQCF system. Manteca shall

update the industrial user inventory annually and provide a copy of the inventory to

Lathrop by December 15t11 of each year. The industrial user inventory shall contain the

name of the industrial user, the address, telephone number of the facility, the standard

392793-2

industrial classification (SIC), and identify the product or service provided by the facility.

Lathrop shall notify Manteca of any additional planned industrial waste discharges to the

WQCF system thirty days -before commencement of the discharge.

7. Before any industrial user located outside the jurisdictional boundaries of Lathrop

discharges into the WQCF Sewer system, Lathrop and Manteca shall enter into an

agreement with the jurisdiction in which such industry is located. Such agreement shall

be substantially equivalent to this Agreement and must be entered into prior to a

discharge from any such industrial user.

8. Manteca may recover costs for permitting, inspecting, sampling, and other industrial user

monitoring and enforcement activities directly from the industrial dischargers located

within Lathrop’ s jurisdiction.

9. If any term of this Agreement is held to be invalid in any judicial action, the remaining

terms shall be unaffected.

10. Manteca and Lathrop shall review and revise this Agreement to ensure compliance with

the Federal Clean Water Act (42 U.S.C. § 1251 et seq.) and rules and regulations (see 40

CFR part 403) issued thereunder, as necessary, but at least once every 5 years on a date to

be determined by Manteca and Lathrop.

11. This Agreement shall remain in effect so long as Agreement A765 remains in effect.

Termination of the Agreement A765 shall also result in the termination of this

Agreement.

12. If the authority of Manteca to act as agent for Lathrop under this Agreement is questioned

by an industrial user, court of law, or otherwise, Lathrop shall take whatever action is

necessary to ensure the implementation and enforcement of its waste ordinance against

its industrial dischargers, including, but not limited to, implementing and enforcing its

waste ordinance on its own behalf and/or amending this Agreement to clarify Manteca’s

authority.

13. Any disputes between Manteca and Lathrop arising out of this Agreement shall be

submitted to binding arbitration performed in accordance with the rules of American

Arbitration Association.

CITY OF LATHROP CITY OF MANTECA

By: ______________________ By: ________________________

Its Its

Appendix C - Element 4 (Operations & Maintenance)

City of Lathrop Sewer System Management Plan C-1

APPENDIX C – Element 4 (Operations & Maintenance) Supporting Documents

1. Figure C-1. City of Lathrop Wastewater Infrastructure

2. Figure C-2. City of Lathrop Sewer Collection Systems and Pump Station Drainage Areas

3. Sewer Flushing Report Form

4. Daily Lift Station Inspections Report Form

5. Pump Inspection Report Form

6. 12-Inch Force Main to Manteca Inspection Report

7. Air/Vacuum Release Valve Report

8. Table C-1. Wastewater Pump Station Pump and Motor Information

Appendix C - Element 4 (Operations Maintenance)

Table C-1

Wastewater Pump Station Pump and Motor Information

Pump StationNumber of

Pumps

Force Main

Diameter (in)

Design Capacity

(gpm)

Firm Capacity

(gpm)Horse Power Pump Model

MWQCF Collection SystemNorth Harlan PS 2 6" 250 245 10 HP (2) FLYGT CP3127 IMP#438 (2)

Stonebridge LS 2 6" 410 380 10 HP (2)FLYGT N3127 IMP#489

FLYGT CP3127 IMP#2196Woodfield LS 2 8" 1,380 750 5 HP (2) FLYGT N3102Valley Crossing LS 2 4" 83 (a) 83 (a) 3 HP (2) FLYGT CP3085 IMP#434J Street LS 2 8" 800 625 10 HP (2) FLYGT N3127 IMP#188 (2)Easy Court LS 2 - 1,000 500 3 HP (2) FLYGT N3085 IMP#135

O Street PS 3 12" 1,850 1,57570 HP (2)

5 HP

FLYGT NP3202 IMP#456(2)

5 HP Pump Model Unknown

McKinley Avenue PS 3 16" 2,550 1,67025 HP (2)

5 HP

FLYGT N3171 IMP#455 (2)

FLYGT N3085 IMP#462Louise Avenue PS 2 4" (b) (b) 5 HP (2) FLYGT N3085 IMP#463 (2)

Lathrop CTF Collection SystemCentral Lathrop Low Flow PS 1 4" 87 -- 4 HP FLYGT NP3085 SHMossdale PS 4 8" & 12" 1,900 1,800 30 HP (4) FLYGT NP3171 IMP#454 (4)River Islands Interim PS 1 12" 1,150 -- 20 HP FLYGT N3153 IMP#433

Crossroads PS 2 8" 860 570 10 HP (2)FLYGT CP3127 IMP#483

FLYGT NP3127 IMP#488

Notes:

(a) Capacity of the downstream 8" gravity main is listed as the lift station capacity, as the pumps are capacity to convey flow beyond this flow rate.

(b) Pump station capacity depends on flows through the 16-inch force main to MWQCF.


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Notes1. All locations are approximate.

Sources1. Aerial photograph provided by ESRI's ArcGIS Online, 23 January 2018.

Legend

DRAFT

± 0 2,500 5,000(Scale in Feet)

City of Lathrop Wastewater Infrastructure

Lathrop, CAJanuary 2018

B60038.02Figure C-1

City of Lathrop

= Central Lathrop Specific Plan= Consolidated Treatment Facility= Lathrop Industrial Park= lift station= Manteca Water Quality Control Facility= pump station= Super Store Industries= wastewater treatment facility

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Legend

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City of Lathrop Sewer Collection Systemsand Pump Station Drainage Areas


B60038.02Figure C-2

City of Lathrop


Pump Station Drainage Area

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CITY OF LATHROP

SEWER FLUSHING REPORT

Page 1 of 2

Line Information:

Date: Operators:

Line Location: Line Material: Ft. of Run:

No. of Runs to Clear Line: Condition of Line:

Description of Material or Damage to Line:

Upstream Line Information:

Location of Manhole:

Depth to Invert: Grout Condition:

Lid Condition: Manhole Material:

Drop Manhole? Y or N No. of Services in Manhole

Evidence of Flooding Due to Backup:

Description of Material in Manhole:



CITY OF LATHROP

SEWER FLUSHING REPORT

Page 2 of 2

Downstream Line Information:

Location of Manhole:

Depth to Invert: Grout Condition:

Lid Condition: Manhole Material:

Drop Manhole? Y or N No. of Services in

Manhole

Evidence of Flooding Due to Backup:

Description of Material in Manhole:

Sewer Plug Callout Information: To be Filled Out on Call Out Only

Name of Caller: Address of Caller:

Phone # of Caller: Customer C.O. Checked? Y or N

Plug on Customer

Side?

Cleaned From C.O. to Main? Y or

N

No. of Feet to Main Line Plug?

Description of Removed From Main Line:

Reviewed By:

Action Taken:

Forwarded To: File Supervisor P.W. Director



CITY OF LATHROP

DAILY LIFT STATION INSPECTION REPORT

Page 1 of 2

Lift Station: Date:

Day

Pump Run Times, hrs

Initials Pump A Pump B Pump C Total for

Day Counter Elapsed Counter Elapsed Counter Elapsed

1

2

3

4

5

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7

8

9

10

11

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13

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15

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31



CITY OF LATHROP

DAILY LIFT STATION INSPECTION REPORT

Page 2 of 2

Lift Station: Date:

Day

Station

Alarm

Triggered

(Yes/No)

Pumps

Free of

Grease &

Debris

Wet Well

Drawn

Down &

Washed

Pumps

OK

Generator

OK

Pumps

Left in

Auto

(Yes/No)

Comments

1

2

3

4

5

6

7

8

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31



CITY OF LATHROP

PUMP INSPECTION REPORT

Lift

Station:

Pump # Nameplate

Info:

Model #: SN #:

KW: HP: Volts: Amps:

Phase: HZ: RPM:

Date of

Inspection:

Operator:

Start

Time:

Finish Time:

1. Pump Inspection

Oil Level Oil Condition Oil Added Wear Ring

Case Cond. Volute Cond. Lift Strap Guide Bar

Pull Cable Cord Seal Cord Cond. Wet Well

Noise? Vibration? Bubbler Cond. Float

Cond.

2. Electrical Panel Inspection

Panel Clean? Panel Door

Seal

Panel Warning Light

HOA Switch Starter Noise? Overload Setting

Amperage Draw,

T1

T2 T3

Heat Discoloration?

List Discrepancies, Corrections Made, Comments, and Recommendations:

Reviewed By:

Action Taken:




CITY OF LATHROP

12 INCH FORCE MAIN TO MANTECA INSPECTION REPORT

Operator(s):

Date:

Evidence of Leak(s) (Yes/No):

Location of Leak(s):

Notifications to:

Written Report Required (Yes/No):

Condition of Alignment:

Repairs Required:

Encroachment(s) onto Alignment (Yes/No):

Type of Encroachment(s) onto Alignment:

Comments:

Reviewed By:

Action Taken:




CITY OF LATHROP

AIR/VACUUM RELEASE VALVE REPORT

ARV Number:

Date:

Operators:

Evidence of Overflows Contained in Manhole? (Yes/No)

Condition of Ball Valve:

ARV Exercised:

Air Release Inspected:

Vacuum Break Inspected:

Items or Seals Replaced:

Comments:

Reviewed By:

Action Taken:


Appendix D - Element 6: (Overflow Emergency Response Plan)

City of Lathrop Sewer System Management Plan D-1

APPENDIX D – Element 6 (Overflow Emergency Response Plan) Supporting Documents


2. Overflow Emergency Response Plan SSO Reporting Chain of Communication

3. Overflow Emergency Response Plan List of Contacts

4. Procedures for Estimating the Volume of Sewer Overflows

5. Sanitary Sewer Overflow Report Form



OVERFLOW EMERGENCY RESPONSE PLAN

PURPOSE

This Overflow Emergency Response Plan is prepared to protect public health and the environment,

satisfy regulatory agencies and waste discharge permit conditions for managing Sanitary Sewer

Overflows (SSOs), and minimize risk of enforcement actions against the City in the event of an

overflow.

PROCEDURES

I. Overflow Detection

City employees, contractors, or the public may detect an overflow. The Public Works

Department (PWD) is primarily responsible for receiving phone calls from the public

notifying the City of possible overflows from the wastewater conveyance system. The

emergency response shall be available 24 hours per day, 365 days per year. During normal

working hours, the call will be routed to the PWD receptionist. During off-hours the call

will be routed to the PWD on-call employee. The PWD receptionist or on-call employee

receiving the call will be responsible for the following procedures:

1) First Step – Record information from the caller regarding the incidence. At a

minimum, the following information should be recorded when taking the call:

(a) Full name of caller (first/last name)

(b) Caller’s contact information (phone number, address, company name, etc.)

(c) Date and time call received

(d) Location of possible overflow (address and nearest cross street)

(e) Description of the problem

(f) Time problem was first observed by the caller

(g) Observations of the caller

(h) Other relevant information that will enable the PWD to quickly locate, assess,

and stop the overflow (e.g. estimated spill volume, suspected cause of spill, are

any hazardous chemicals involved)

2) Second Step – After completing the call, notify operations and maintenance

(O&M) staff as soon as possible in the following order (move to the next person on

the list if no answer to first caller):

(a) Milton Daley, O&M Superintendent

(b) PWD Admin Staff Person doing Work Orders

(c) On-call O&M Staff Person



3) Third Step – Send an email with the following information to the Emergency Spill

Response Group (distribution list found in outlook)

(a) Information taken from call (First Step)

(b) Name of employee whom spill was reported to (Second Step)

4) Fourth Step (if applies)

(a) After the initial call, we may have other callers reporting the spill. Please take

their name & number and return their call once the problem has been resolved.

The SCADA system will automatically dial the on-call O&M staff in the event of

equipment failure or detection of a possible overflow. Sanitary sewer overflows detected

by the SCADA system or any personnel in the course of their normal duties shall be

immediately reported to their supervisor.

II. Initial Response

Failure of any element within the City-owned and operated wastewater conveyance system

that threatens to cause or causes a SSO will trigger a response to isolate and correct the

problem. Crews and equipment shall be available to respond to any sewer overflow

locations.

Upon receipt of a report of sewage overflow, all response crew members shall proceed to

the Corporate Yard where they will gather all necessary equipment and resources before

proceeding to the site of the SSO. Delays or conflicts in assignments and issues regarding

equipment and resources should be reported to their supervisor.

In the event of a spill or overflow, it is the responder’s role to protect public health, the

environment, and property from wastewater overflows and to restore the area to normal as

soon as possible. Specifically, the responder should:

• Upon arrival at the site of the SSO, note the time of arrival, assess the situation,

develop an approach to contain the sewage and eliminate the cause of the overflow.

• Take photographs if time permits.

• Dispatch crews shall promptly notify their supervisor, if available, of preliminary

information and potential impacts. If the supervisor is not available, the O&M

Superintendent should be notified.

• Immediately notify the O&M Superintendent or the Public Works Director by

telephone of all sanitary sewer overflows that could be greater than 1,000 gallons,

that may have entered a body of water or that may have caused damage to private

property.

• Establish safety parameter and control zones with cones, barricade, signs, vehicles

or terrain.

• If hazardous conditions that may cause illness or injury are encountered,

immediately notify the O&M Superintendent for guidance before taking further

action.



o The O&M Superintendent shall alert the Lathrop Manteca Fire Department

(LMFD) and request a hazardous materials response team.

o The maintenance personnel shall wait until the LMFD hazardous materials

response team has determined it is safe for the sewer maintenance response

team to proceed with containment, and cleanup activities.

• Contain or divert sewage, if possible, to prevent entry into a storm drain, body of

water or environmentally sensitive areas. Use earthen berms, sand bags, air plugs

in storm drains, vacuum unit or other available methods to contain or divert the

flow. Determine if bypass pumping is feasible and, if so, have support staff divert

flow around the blockage to the downstream manhole.

• Eliminate the cause of the overflow and restore the flow in the collection system.

In most cases, this will be accomplished by removing a root, grease, or debris

blockage in the sewer pipe using a hydrojet. Note the time that the flow is restored.

• If the blockage cannot be removed within 30 minutes of arrival, notify the

maintenance supervisor, the O&M Superintendent, or the Public Works Director

immediately. Remain on site and follow directions.

• After the overflow has been stopped and repairs have been made, return any sewage

that can be collected back to the sewer system using the vacuum unit or trash pump.

Note the time this activity began.

• If the blockage is in a private lateral, notify the property owner of the blockage and

inform them that the City does not own or maintain private service laterals. Suggest

the property owner to hire a contractor to clear their line.

III. Recovery and Clean-up (Mitigation)

Perform site clean-up by removing signs of all gross contamination such as toilet paper,

solids, and grease with a rake or with a vacuum unit. Wash down the affected area with

clean water, contain the water, and dispose of the water in the sewer. In environmentally

sensitive areas, obtain guidance from the governing state and federal agencies, such as the

California Department of Fish and Wildlife or the United States Fish and Wildlife Service,

on clean up procedures to prevent causing more damage. Clean up procedures in sensitive

areas may cause more harm than the sewer overflow event.

The potential for human health issues and adverse environmental impacts resulting from

sanitary sewer overflows can be reduced by following these clean up and mitigation

procedures. The procedures described are for dry weather conditions. During wet weather

conditions modify these procedures as necessary when storm waters are high and flushing

is impractical. Cleanup flushing should be accomplished only with clean water.

Paved Areas

Collect all signs of gross contamination by hand or with the use of rakes or brooms as

appropriate and dispose as solid waste. Pressure-wash the affected area with clean water

until the wash water is clear. Contain and vacuum the wash water. Allow the affected area

to dry and repeat the process if necessary. For paved areas on private property, use a

disinfectant solution for the final flush.



Areas with Bare Soil or Vegetation

Collect all signs of gross contamination by hand or with the use of rakes as appropriate and

dispose as solid waste. Flush the affected area with clean water until the wash water is

clear. The volume of the flushing water should be approximately three times the amount

of sanitary sewage volume that contaminated the area. Contain and vacuum up the wash

water. Allow the affected area to dry and repeat the process if necessary.

Environmentally Sensitive Areas

Environmentally sensitive areas include streams, creeks and riparian habitat. Obtain

guidance from the governing state and federal agencies if an environmentally sensitive area

is impacted. In some cases, the disturbance caused by cleanup activities may be more

damaging than the sewer overflow event. Divert and contain sewage quickly to minimize

impact to these areas. Any water used to clean up these areas should be de-chlorinated prior

to use to minimize impacts to aquatic life.

IV. Public Access and Warning

Set up barricades and post warning signs in cases where public health may be at risk by

contact with sewage or sewage contamination. Warning signs should contain the words

“Raw Sewage, Avoid Contact”. Place the barricades and signs at points of public access in

an effort to warn the public in that immediate area.

Inspect all sewer overflow locations the following day. Identify any signs of gross

contamination. Verify whether barricades and warning signs are still needed and whether

the signs are still in place, especially at points of public access.

Check barricade signs daily until approval to remove signs is received from the San Joaquin

County Department of Environmental Health.

V. Water Quality Sampling and Analysis

Water quality samples shall be taken in any body of water receiving sewage to determine

the extent of the contamination. Water quality sampling should be performed to:

1. Determine the extent of the area that has been impacted by sewage contamination; and

2. Determine when the area is safe for public contact.

Perform water quality sampling when it is suspected that over 1,000 gallons of sewage has

entered a body of water or if there is a large, noticeable discharge and/or pooling of

wastewater entering or potentially entering a creek or waterway.

Water quality sampling should be performed by trained City personnel or through a water

quality testing laboratory that is under contract with the City.

If water quality samples are taken, the following information should be recorded:

• The date, exact place, and time of sampling or measurements.



• The individual(s) who performed the sampling or measurements.

• The date(s) analyses were performed.

• The individual(s) who performed the analyses.

• The analytical technique or method used.

• The results of such analyses.

Sampling and Testing Procedures by City Staff

Sampling for ammonia should be conducted both upstream and downstream of the point

where sewage entered the receiving water. Ammonia is a unique indicator of sewage

contamination. Samples should be taken every 50 feet both upstream and downstream of

the point where sewage entered the receiving water until ammonia is no longer detected in

the receiving water. The testing is inexpensive and fast and will determine the limits of

sewage contamination. The sampling and analysis should be performed following the

directions contained in the Nitrogen Ammonia Test Strip Kit (www.hach.com) and the

results recorded. More comprehensive testing should be performed on portions of the water

body shown to be positive for ammonia. Samples should be analyzed for total coliform,

fecal coliform, and dissolved oxygen. Each sampling location should be documented and

follow up sampling should be performed in the same sampling locations for affected areas.

Testing by San Joaquin Department of Environmental Health

The City should inform the San Joaquin County Department of Environmental Health

(SJCDEH) of any sewage contamination in a body of water that may pose a threat to human

health. This provides the SJCDEH the opportunity to perform water sampling and testing

and make the final determination that the water body is no longer contaminated.

VI. Investigation and Documentation

Investigate and document all SSOs. This information is useful in determining

modifications to the operations and maintenance program, capital program decision

making, and to respond to regulatory inquiries.

It is the responsibility of the appropriate PWD personnel or the response crew to gather all

spill response data and communicate this data back to the O&M Superintendent as soon as

possible. Information obtained on the SSO shall be reported on a Sanitary Sewer Overflow

Report Form (included in this appendix), and kept in a file created for each SSO event.

Perform a preliminary estimate of the sewer overflow volume using the methods outlined

in this Appendix: Procedures for Estimating the Volume of Sewer Overflows.

Fill out the attached Sanitary Sewer Overflow Report, note time and take photographs prior

to leaving the site.

Submit the Sanitary Sewer Overflow Report. For major SSOs (i.e. SSO Categories 1 and

2), submit the form with immediately available information to the O&M Superintendent or

the Public Works Director as soon as possible. For minor SSOs (i.e. SSO Category 3),

http://www.hach.com/



submit the Internal Overflow Report to the O&M Superintendent or the Public Works

Director by 4:00 P.M. for overflows occurring during business hours or by 9:00 A.M. for

overflows occurring outside of regular business hours (i.e. 8:00AM - 6:00PM Monday –

Thursday; 8:00AM - 5:00 PM Friday).

Sewer Overflow Investigation

The goal of a sewer overflow investigation is to determine the cause of the sewer overflow

and to identify appropriate corrective actions to minimize the recurrence of that type of

event. The investigation should follow immediately after the spill response is complete.

Table E-1 provides a checklist of activities that should be performed following a sewer

overflow.

Table E-1

City of Lathrop


Sewer Overflow Investigation Activities Checklist

SSO Investigation Activities Checklist

Interview field personnel that responded to the sewer

overflow

Review maintenance history of pipes and manholes

where the blockage or failure occurred

Inspect the manhole or sewer pipe where the

blockage or failure occurred using closed circuit

television (CCTV)

Inspect the sewer overflow site and the affected area

Review available flow data and SCADA data (if

appropriate)

Review sewer overflow volume estimate

Review water quality results

Evaluate corrective actions

Record results of investigation on Sewer Overflow

Report

Sewer Overflow Tracking

Sewer overflows should be tracked on a map marking the location of all known sewer

overflows. The map should identify the specific pipe or manhole that contained the

blockage or failure. The sewer overflow event should also be documented in the

maintenance management system.

Sewer Spill Documentation

Each sewer overflow, regardless of volume, should be documented in a unique file. The

file should contain pertinent information that may be necessary to respond to future



regulatory audits or actions. A checklist of the information that should be included in the

sewer overflow documentation file is provided in Table E-2. Use the following guidelines

to document the spill:

1. Provide accurate flow measurements and duration of the spill. Refer to the end of this

Appendix E for methods of sewer overflow volume estimates.

2. Provide a map of the problem location (manhole/s involved) and where the spill discharged

(storm drain, field, stream, City of Lathrop, Sewer System Facilities Map).

3. Take photos of events if possible.

TABLE E-2

SANITARY SEWER OVERFLOW

DOCUMENTATION ACTIVITIES CHECKLIST

Documentation Item In File

Service Call Data:

Date and time received

Caller name

Caller address

Caller telephone number

Location of Sewer overflow

Description of the problem

Sewer Overflow Report

Map showing location of the overflow and the location of the

cause

Notes regarding directions provided by the regulators

Photographs:

Overflow site upon arrival

Actions taken during response (including people, equipment,

activities)

Upon completion of clean up and mitigation

CCTV videotape and inspection pictures showing defects

Record of completion of corrective action

VII. Regulatory Notification and Reporting



State Water Resources Control Board Order No. WQ 2013-0058-EXEC (State Order) for

the Monitoring Reporting Program (MRP) establishes the monitoring, record keeping,

reporting and public notification requirements for Order 2006-003-DWQ, “Statewide

General Waste Discharge requirements for Sanitary Sewer Systems (SSS WDRs)”.

The State Order establishes the following SSO Categories, as defined below:

1. Category 1 - Discharges of untreated or partially treated wastewater of any volume

resulting from an enrollee’s sanitary sewer system failure or flow conditions that:

a. Reach surface water and/or reach a drainage channel tributary to a surface

water; or

b. Reach a municipal separate storm sewer system (MS4) and are not fully

captured and returned to the sanitary sewer system or not otherwise captured

and disposed of properly. Any volume of wastewater not recovered from the

MS4 is considered to have reached surface water unless the storm drain system

discharges to a dedicated storm water or groundwater infiltration basin (e.g.,

infiltration pit, percolation pond).

2. Category 2 – Discharges of untreated or partially treated wastewater greater than or

equal to 1,000 gallons resulting from an enrollee’s sanitary sewer system failure or flow

condition that does not reach a surface water, a drainage channel, or the MS4 unless

the entire SSO volume discharged to the storm drain system is fully recovered and

disposed of properly.

3. Category 3 – All other discharges of untreated or partially treated wastewater resulting

from an enrollee’s sanitary sewer system failure or flow condition.

4. Private Lateral Sewage Discharge (PLSD) – Discharges of untreated or partially

treated wastewater resulting from blockages or other problems within a privately-

owned sewer lateral connected to the City’s sanitary sewer system or other private

sewer assets.

The State Order requires reporting of SSOs using an online SSO Database (Database). To

report SSOs using the Database, the City must establish an account by registering through

the California Integrated Water Quality System (CIWQS). In the event that the Database

is not available, the City is required to fax all the requested information to the appropriate

Regional Board office. The City must also enter all required information into the Database

as soon as practical.

In addition, although not a collection system SSO, overflows may occur at the influent

pump station of the wastewater treatment plant. The plant is contained to prevent overflows

from reaching a surface water, a drainage channel, the MS4. In an event of a treatment

plant overflow, it is recommended that the City follow response procedures outlined above



and notify the Regional Board of the event. A letter report will be required to be submitted

to the Regional Board.

Private Lateral Sewage Discharge Reporting

The City is strongly encouraged to notify California Office of Emergency Services (Cal

OES) of discharges greater than or equal to 1,000 gallons of untreated or partially treated

wastewater that result or may result in a discharge to surface water resulting from failures

or flow conditions within a privately-owned sewer lateral or from other private sewer

asset(s) if the City becomes aware of the PLSD.

Category 1 Sanitary Sewer Overflow Notification Requirements (see section B of

MRP)

For any Category 1 SSO greater than or equal to 1,000 gallons that results in a discharge

to a surface water or spilled in a location where it probably will be discharged to surface

water, either directly or by way of a drainage channel or MS4, the City shall, as soon as

possible, but not later than two (2) hours after (A) the City has knowledge of the discharge,

(B) notification is possible, and (C) notification can be provided without substantially

impeding cleanup or other emergency measures, notify the Cal OES and obtain a

notification control number.

Office of Emergency Services (OES):

Call anytime: (800) 852-7550

To satisfy notification requirements for each applicable SSO, provide the information

requested by Cal OES to receive a spill control number. The following information may be

requested:

1. Name of person notifying Cal OES and direct return phone number.

2. Estimated SSO volume discharged (gallons).

3. If ongoing, estimated SSO discharge rate (gallons per minute).

4. SSO Incident Description:

a. Brief narrative.

b. On-scene point of contact for additional information (name and cell phone

number).

c. Date and time enrollee became aware of the SSO.

d. SSO cause (if known).

5. Indication of whether the SSO has been contained.

6. Indication of whether surface water is impacted.

7. Name of surface water impacted by the SSO, if applicable.

8. Indication of whether a drinking water supply is or may be impacted by the SSO.

9. Any other known SSO impacts.

10. SSO incident location (address, city, state and zip code).

Following the initial notification to Cal OES and until such time that the City certifies the

SSO report in the CIWIQS Online SSO Database, the City shall provide updates to Cal



OES regarding substantial changes to the estimated volume of untreated or partially treated

sewage discharged and any substantial change(s) to known impact(s).

Notification of SSOs to Other Regulatory Agencies:

Other regulatory agencies should be notified depending on the location and/or impacts of

the SSO:

For impacts to recreational swimming areas or similar threats to public health:

Notify the San Joaquin County Department of Environmental Health (SJCDEH): (209)

468-3420.

In case of impacts to the City’s Drinking Water System or water supplies:

Notify the California State Water Resources Control Board, Division of Drinking Water,

District 10 - Stockton: (209) 948-7696

In case of a fish kill:

Immediately notify the California Department of Fish and Wildlife at (916) 227-2245 and

provide updates as needed.

Spill into South San Joaquin Irrigation District (SSJID) Canal:

Contact SSJID at (209) 823-3101.

Other local agencies and individuals that should be notified depending on the

circumstances of the SSO:

City of Manteca:

The City of Manteca should be notified if a sewer overflow from the City’s collection

system occurs in Manteca’s service area. Call during working hours: (209) 456-8470

Internal Managers:

• For all SSOs, Notify the Public Works Maintenance Supervisor;

• Major spills (greater than 1,000 gallons), or those affecting surface water or human

health (SSO Categories 1 and 2), notify the Public Works Director;

• For Major spills (greater than 50,000 gallons), or those affecting surface water or

human health, notify the City Manager.

Police Department: Roadblock, traffic control, etc.

Public Services: Close areas such as parks, shopping centers, etc.

Water Department: Impact on drinking water storage or supply.

In addition, any local residents and businesses that may be impacted.

Reporting Requirements (see Section C of MRP)



All reporting shall be done using the CIWQS Online SSO database

(http://ciwqs.waterboards.ca.gov/), certified by City’s Legally Responsible Official(s).

Category 1 and 2 SSOs: Submit draft report within three business days of becoming aware

of the SSO and certify within 15 calendar days of SSO end date.

Category 3 SSOs: Submit certified report within 30 calendar days of the end of month in

which the SSO occurred.

SSO Technical Report: Submit within 45 calendar days after the end date of any Category 1

SSO in which 50,000 gallons or greater are spilled to surface waters.

Record Keeping Requirements (see Section E of MRP)

The MRP include the following requirements for record keeping.

1. Individual SSO records shall be maintained by the City for a minimum of five years

from the date of the SSO. This period may be extended when requested by a Regional

Board Executive Officer.

2. SSO records shall be made available for review upon State or Regional Board staff’s

request.

3. SSO monitoring instruments and devices that are used by the City to conduct water

quality monitoring for SSOs shall be properly maintained and calibrated as necessary

to ensure their continued accuracy.

4. The City shall retain records of all SSOs, such as, but not limited to and when

applicable:

a. Record of Certified report, as submitted to the Database.

b. All original recordings for continuous monitoring instrumentation.

c. Service call records and complaint logs of calls received by the City.

d. SSO calls.

e. SSO records.

f. Steps that have been and will be taken to prevent the SSO from recurring and a

schedule to implement those steps.

g. Work orders, work completed, and any other maintenance records from the

previous 5 years which are associated with responses and investigations of system

problems related to SSOs.

h. A list and description of complaints from customers or others from the previous 5

years.

i. Documentation of performance and implementation measures for the previous 5

years.

VIII. Equipment

http://ciwqs.waterboards.ca.gov/



This section provides a list of City-specialized equipment required to support this OERP.

VacCon Truck

A VacCon truck is required to clear blockages in gravity sewers and to vacuum up spilled

sewage. The truck can also be used for wash down and cleanup.

Portable Pumps and Hoses

Portable pumps ranging in size from 2” to 6” are required to pump spilled sewage and/or

contaminated water back into the sewer system.

Street Sweeper

A street sweeper may be used to assist in the cleanup of roadways and parking lots.

Closed Circuit Television (CCTV) Inspection Unit (or Lateral Inspection Unit)

A portable CCTV Inspection Unit is required to determine the root cause of all SSOs from

gravity sewers. CCTV inspection services can be provided by a contractor.

Emergency Response Truck(s)/Trailer

A utility body truck and/or trailer is required to store and transport the equipment needed to

effectively respond to sewer emergencies. The equipment and tools should include an electric

eel rodding machine, sectional rods, generator, lights, and spill containment and cleanup

materials.

Photographic Equipment

A digital, instant, or disposable camera is required to record the conditions upon arrival, during

cleanup, and upon departure.

GPS Unit

A hand-held GPS unit (Global Positioning System) is required to determine the coordinates

of spills for use in meeting RWQCB SSO reporting requirements.

IX. Training

This section provides information on the training that is required to support this OERP.

Initial and Annual Refresher Training

All Wastewater Section personnel and Duty personnel should be trained in sewage

overflow response, which includes this plan. The training program should be updated

annually.

All employees who may have a role in responding to, reporting, and/or mitigating a sewer

system overflow should receive training. All new employees should receive training before

they are placed in a position where they may have to respond. Current employees should

receive annual refresher training on this plan and the procedures to be followed.

SSO Response Exercises

Periodic training exercises will be held to ensure that employees are up to date on the

procedures, to verify the equipment is in working order, and the required materials are



readily available. The training exercises should cover scenarios typically observed during

sewer-related emergencies (e.g. mainline blockage, mainline failure, force main failure,

pump station failure, and lateral blockage). The results and the observations during the

exercises should be recorded and action items should be tracked to ensure completion.

Record Keeping

Records shall be kept of all training that is provided in support of this plan. The records for

all scheduled training courses and for each overflow emergency response training event

should include date, time, place, content, name of trainer(s), and names of attendees.



CITY OF LATHROP


SSO REPORTING CHAIN OF COMMUNICATION



CITY OF LATHROP


LIST OF CONTACTS

Contact Phone Number Email Address

Public Works After Hours Emergency (209) 992-0028

Milton Daley, O&M Superintendent (209) 941-7475 (office)

(209) 992-0044 (mobile)

[email protected]

Michael Dunn, Utility Operator (209) 992-0021 [email protected]

Chris Hart, Utility Operator (209) 992-0019 [email protected]

Public Works Director (209) 941-7499 (office)

--

Greg Gibson, Senior Civil Engineer (209) 941-7442 (office)

(209) 992-0017 (mobile)

[email protected]

Michael King, Senior Civil Engineer (209) 941-7454 (office)

(209) 992-0733 (mobile)

[email protected]

Emilia Knox, Senior Admin Assistant (209) 941-7435 [email protected]

Veronica Hedges, Senior Admin

Assistant


Teresa Vargas, City Clerk (209) 941-7431 [email protected]

Stephen Salvatore, City Manager (209) 941-7491 (office)

(209) 992-0014 (mobile)

[email protected]

Lathrop Fire Department - J Street

Station

(209) 941-5100

Lathrop Police Department (209) 468-4400

Paul Zolfarelli, Project Manager,

VWNA (Lathrop CTF)

(209) 858-1645 (office)

(209) 406-3845 (mobile)

[email protected]

mailto:[email protected]










PROCEDURES FOR ESTIMATING VOLUME OF SEWER OVERFLOWS

A variety of approaches exist for estimating the volume of a sanitary sewer overflow. This

appendix documents five approaches that can be used. The individual preparing the estimate

should select the approach most appropriate to the sewer overflow in question using the best

information available. Every effort should be made to make the best possible estimate of the

volume. Assistance from the engineering group within the PWD should be sought for larger sewer

overflows.

Upstream Connections

If the flow is coming from a cleanout or a broken line, count the number of upstream connections

and estimate the time that the flow has been occurring. Remember that the flow was probably

flowing before noticed and reported. Each residence contributes about 245 gallons per day per

connection or about 10 gallons per hour. Multiply the number of residences by 245 or 10 and by

the number of days or hours, respectively. This provides the number of gallons.

Visual Estimate

If the flow is coming from a manhole, use the photographs in this appendix to estimate the flow.

Select which photograph in gallons per minute is similar to the overflow you are experiencing and

multiply it by 60, then multiply this by the estimated number of hours the overflow has been

occurring. This will estimate the amount of overflow in gallons.

Pump Station Estimate

If the flow is coming from a pump station, use the previous days (same weather) flow and pump

capacity to estimate the flow.

Eyeball Estimate

The volume of very small spills can be estimated using an eyeball estimate. To use this method,

imagine the amount of water that would spill from a bucket or a barrel. A bucket contains 5 gallons

and a barrel contains 50 gallons. If the spill is larger than 50 gallons, try to break the standing

water into barrels and then multiply by 50 gallons. This method is useful for contained spills up

to 100 gallons.

Measured Volume

The volume of most spills can be estimated using this method. The shape, dimension and depth

of the spilled wastewater are needed. The shape and dimension are used to calculate the area of

the spill and the depth is used to calculate the volume.

1. Sketch the shape of the contained sewage.

2. Measure or pace off the dimensions.

3. Measure the depth at several locations.

4. Convert the dimensions, including depth, to feet.



5. Calculate the area using the following formulas:

Rectangle Area = length x width

Circle Area = diameter x 3.14

Triangle Area = ½ x base x height

6. Multiply the area times the depth.

7. Multiply the volume by 7.5 to convert to gallons.

Duration and Flow Rate

Calculating the volume of spills where it is difficult or impossible to measure the area and depth

requires a different approach. In this method, separate estimates are made of duration of the spill

and the flow rate. The methods of estimating duration and flow rates are:

1. Duration: The duration is the elapsed time from the start of the spill to the time the spill

stopped.

2. Start Time: This is sometimes difficult to establish. Three methods to establish start time are

as follows:

a. Local residents can be used to establish start time. Inquire as to their observations. Spills

that occur in rights-of-ways are usually observed and reported in short order. Spills that

occur out of public view can go on longer. Sometimes, observations like odors or sounds

(e.g. water running in a normally dry creek bed) can be used to estimate the start time.

b. Changes in flow on a downstream flow meter can be used to establish the start time.

Typically, the daily flow peaks are cut off or flattened by the loss of flow. This can be

identified by comparing hourly flow data, when available.

c. Conditions at the spill site change with time. Initially, there will be limited deposits of

grease and toilet paper. After a few days to a week, the grease forms a light colored residue.

After a few weeks to a month, the grease turns dark. In both cases, the quantity toilet paper

and other materials of sewage origin increase in amount. These changes with time can be

used to estimate the start time in the absence of other information.

3. End Time: This is much easier to establish. Field crews on-site observe the blow down that

occurs when the blockage has been removed. The blow down can be observed in downstream

flow meters.

4. Flow Rate: The flow rate is the average flow that left the sewer system during the time of the

spill. There are three ways to estimate the flow rate:

a. Manhole flow rate chart: This chart shows the sewage flowing from a manhole cover for a

variety of flow rates. The observations of the field crew are used to select the approximate

flow rate from the chart.



b. Flow meter: Changes in flows in the downstream flow meters can be used to estimate the

flow rate during the spill.

c. Once the location is known, the number of upstream connections can be determined from

the field books. Multiply the number of residences by 245 gallons per day per connection

or 10 gallons per hour per connection.

Once duration and flow rate have been estimated, the volume of the spill is calculated by

multiplying the duration in hours or days times the flow rate in gallons per hour or gallons per

day.



ESTIMATING WASTEWATER FLOWS



SANITARY SEWER OVERFLOW REPORT FORM

Spill Name (Location): Date:

This report is (check one): Preliminary ____ Final ____ Revised Final____

Sewer System (check one): WRP-1(MBR) ____ Manteca WQCF ____ Crossroads____

Initial Contact Information (attach additional sheets if necessary)

Full name of caller (first/last name):_________________________________________________

Phone number (home/office); _______________ (cell/alternate) ________________

Caller Street Address:___________________________________________________________

Date Call Received:_____________ Time Call Received: _____________ AM/PM (circle one)

Location of possible overflow (address and nearest cross street):__________________________

_____________________________________________________________________________

Description of the problem:_______________________________________________________

Time problem was first observed by the caller: ______________ AM/PM

Observations of the caller:________________________________________________________

_____________________________________________________________________________

Other relevant information that will enable the PWD or other first responders to quickly locate,

assess and stop the overflow (e.g. estimated spill volume, suspected cause of spill, are there any

hazardous chemicals involved):____________________________________________________

_____________________________________________________________________________

CIWQS Spill Report – General Information:

1. Spill Type (check one): Category 1_____ Category 2 _____ Category 3______ Private

Lateral Sewage Discharge _____

2. Estimate Spill Volumes:

a) Estimated spill volume that reached a separate storm drain that flows to a surface water body?

__________ gallons.

b) Estimated spill volume recovered from the separate storm drain that flows to a surface water body?

(do not include water used for clean-up) ___ gallons



c) Estimated spill volume that reached a drainage channel that flows to a surface water body?

_____________ gallons.

d) Estimated spill volume recovered from a drainage channel that flows to a surface water body?

____________ gallons.

e) Estimated spill volume discharged directly to a surface water body? __________ gallons.

f) Estimated spill volume reovered from a surface water body? ______________ gallons.

g) Estimated spill volume discharged to land? (Includes discharges directly to land, and discharges

to a storm drain system or drainage channel that flows to a storm water infiltration/retention

structure, field or other non-surface water location.) ___________ gallons.

h) Estimated spill volume recovered from the discharge to land (Do not include water used for clean-

up) ____________ gallons.

Estimated Total spill

volume to reach surface

water (a+b+c+e)


volume to Reach Land

(g)


volume Recovered

(b+d+f+h)


volume

(a+c+e+g)

3. Did the spill discharge to a drainage channel and/or surface water? __________ (yes/no)

4. Did the spill reach a storm drainpipe that is not part of a combined sewer system? ___________

(yes/no)

5. If spill reached a separate storm drainpipe, was all of the wastewater fully captured from the

separate storm drain and returned to the sanitary sewer system? ________ (yes/no)

Physical Location Details

6. Spill location name:

7. Latitude of spill location: _____ deg. _____ min. _____sec. OR decimal degrees

8. Longitude of spill location: _____ deg. _____ min. _____sec. OR decimal degrees

9. County: San Joaquin

10. Regional Water Quality Control Board: Region 5S - Central Valley



11. Spill location description:

Spill Details

12. Number of appearance points: _________

13. Spill appearance point (see key below):

14. Spill appearance point explanation (required if spill appearance point is “Other” and/or multiple

appearance points are selected): ____________________________________________________

15. Final spill destination (see key below):

16. Final spill destination explanation (required if spill destination is “Other”): _________________

______________________________________________________________________________

17. Estimated spill start date/time: ____________ (MM/DD/YYYY) ___:___ AM/PM

18. Date and time sanitary sewer system agency was notified of or discovered spill:

____________ (MM/DD/YYYY) ___:___ AM/PM

19. Estimated Operator arrival date & time: ____________ (MM/DD/YYYY) ___:___ AM/PM

20. Estimated spill end date & time: ____________ (MM/DD/YYYY) ___:___ AM/PM

21. Spill Cause (see key below):

22. Spill cause explanation (required if Spill Cause is “Other”:

23. Where did failure occur? (see key below)

24. Explanation of Where Failure Occurred (required if Where Failure Occurred is “Other”): ______

25. Was the spill associated with a storm event? ________ (yes/no):

26. Diameter of sewer pipe at the point of blockage or failure: _____ inches

27. Material of sewer pipe at the point of blockage or failure: _____ inches

28. Estimated age of sewer pipe at the point of blockage or spill cause (if applicable): _____ years

29. Spill response activities:

30. Explanation of spill response activities (required if spill response activities is “Other”):

31. Spill response completion date & time: ____________ (MM/DD/YYYY) ___:___ AM/PM

32. Spill corrective action taken: ______________________________________________________



33. Explanation of spill corrective action taken (required if spill corrective action is “Other”):

34a - Is there an ongoing investigation?:

34b - Reason for ongoing investigation?:

35. Visual inspection results from impacted receiving water:

36. Health warnings posted? (yes/no)

37. Did the spill result in beach closure? (if YES, answer question 38): ________ (yes/no)

38. Name of impacted beach(es) (enter NA if none):

39. Name of impacted surface water(s) (enter Un-named Tributary to XXXXX where XXXXX is the

name of first named downstream tributary if receiving surface water body is un-named):

40. Water quality samples analyzed for:

41. Explanation of water quality samples analyzed for (required if water quality samples analyzed for

is “Other chemical indicator(s), “Biological indicators”, or “Other”):

42. Water quality samples reported to:

43. Explanation of water quality sample results reported to (required if water quality sample results

reported to is “Other”):

44. Explanation of volume estimation methods used (describe how you developed the spill volume

estimates for this spill):

Notification Details

45. OES Control Number :

(Required for Category 1 – see SSO Monitoring and Reporting Program Requirements)

46. OES Called Date & Time; ____________ (MM/DD/YY) ___:___ AM/PM

(Required for Category 1 – see SSO Monitoring and Reporting Program Requirements)

47 (a) – Name and Title (Contact person who can answer specific questions about this SSO):

47 (b) – Contact Person Phone Number:



CIWQS SSO Report Response Key to Questions #13, 15, 21, 23

13. Spill Appearance Points

• Combined Sewer DI (Combined CS Only – N/A for Lathrop)

• Force Main

• Gravity Mainline

• Inside Building or Structure

• Lateral Clean Out (Private)

• Lateral Clean Out (Public)

• Lower Lateral (Private)

• Lower Lateral (Public)

• Manhole

• Other sewer system structure (specify in response to question #14)

• Pump Station

• Upper Lateral (Private)

• Upper Lateral (Public)

15. Final Spill Destination

• Beach

• Building or Structure

• Combined Storm Drain (Combined CS only – N/A for Lathrop)

• Drainage Channel

• Other (specify in response to question #16)

• Paved Surface

• Separate Storm Drain

• Street/Curb and Gutter

• Surface Water

• Unpaved Surface

21. Spill Cause

• Air Relief Valve (ARV)/Blow-off Valve (BOV) Failure

• Construction Diversion Failure

• CS Maintenance Caused Spill/Damage

• Damage by Others Not Related to CS Construction/Maintenance (specify in response to

question #22)

• Debris from Construction

• Debris from Lateral

• Debris – General

• Debris – Rags

• Flow Exceeded Capacity (Separate CS Only)

• Grease Deposition (FOG)

• Inappropriate Discharge to CS

• Natural Disaster

• Non-Dispersables



• Operator Error


• Pipe Structural Problem/Failure

• Pipe Structural Problem/Failure – Installation

• Pump Station Failure – Controls

• Pump Station Failure – Mechanical

• Pump Station Failure – Power

• Rainfall Exceeded Design I and I (Separate CS Only)

• Root Intrusion

• Siphon Failure

• Surcharged Pipe (Combined CS Only – N/A for Lathrop)

• Vandalism

23. Where did failure occur?

• Air Relief Valve (ARV)/Blow-off Valve (BOV)

• Force Main

• Gravity Mainline

• Lower Lateral (Public)

• Manhole


• Pump Station – Controls

• Pump Station – Mechanical

• Pump Station – Power

• Siphon

• Upper Lateral (Public)

Appendix E - Element 7: (Fats Oils and Grease (FOG) Control Program)

City of Lathrop Sewer System Management Plan E-1

APPENDIX E – Element 7 (Fats Oils and Grease (FOG) Control Program) Supporting Documents

1. Table F-1. List of Food Facilities in Lathrop

2. Figure F-1. Location of Food Facilities in Lathrop

3. City of Lathrop - Industrial Pretreatment Program, Implementation Procedures

4. “Preventing Sewer Backups” public outreach brochure.



Table F-1. List of food facilities in Lathrop

Business Name Street Address

A & L Chinese 16438 Cambridge Dr

Amici Sushi 269 E Louise Ave

Baskin Robbins 15108 S Harlan Rd

Bella's Bakery 155 E Lathrop Rd

Bullock's BBQ 813 Sugar Pine Dr

Burger King 22460 15119 S Harlan Rd

Cafe Platano Bar & Grill 14725 S Harlan Rd

Carl's Jr. Restaurants 200 E Louise Ave

Chicagos Pizza 159 Lathrop Rd

China Wok Express 15020 S Harlan Rd

CK Grill Bar 14725 S Harlan Rd

Comfort Inn - Sandip Patel 14730 S Harlan Rd

Days Inn 14750 S Harlan Rd

Denny's 16851 S Harlan Rd

Denny's Restaurant 16851 S Harlan Rd

Dickey's BBQ 15338 S Harlan Rd

Flying J Travel Plaza # 1017 - Cinnabon 345 Roth Rd

Flying J Travel Plaza #1017 - PJ Fresh 345 Roth Rd

Ghirardelli Chocolate 11980 S Harlan Rd

Golden Bowl Restaurant 2490 W Louise Ave

Hampton Inn & Suites 103 E Louise Ave

Jack In the Box 100 E Louise Ave

KFC / A & W Leha 219 Inc 150 E Louise Ave

Krispy Krunchy Chicken 15600 S Harlan Rd

La Costa de Acapulco 16444 Cambridge Dr

La Hacienda Taqueria 15158 S Harlan Rd

Lathrop Gas & Food 140 E Lathrop Rd

Little Caesar's Pizza 15344 S Harlan Rd

McDonald's 8195 300 E Louise Ave

Mikasa Japanese Bistro 15138 S Harlan Rd

Milan's Pizza 15030 S Harlan Rd



Business Name Street Address

Mountain Mikes Pizza 229 E Louise Ave

MX Donuts 15126 S Harlan Rd

Papa Murphy's Pizza 15124 S Harlan Rd

Popeyes 16837 S Harlan Rd

Quality Inn & Suites 16855 S Old Harlan Rd

Quizno's Subs 209 E Louise Ave

Rasoi 15106 S Harlan Rd

Royal Pizza 159 Lathrop Rd

Siena Italian Restaurant 16925 S Harlan Rd

Starbucks Coffee #10220 15010 S Harlan Rd

Subway 15328 S Harlan Rd

Taqueria Los Primos 16444 Cambridge Dr

Taqueria Vallarta #2 245 E Louise Ave

The Boathouse 980 Lakeside Dr

Togos Lathrop 15600 S Harlan Rd

Yan Yan Deli 151 E Lathrop Rd

YOSEMITE AV

LATHROP RD

MCKI

NLEY

AV

LOUISE AV

DOS REIS RD

DE LIMA RD

ISLA

NDS PKWY

R IV ER

GO

LDEN

VALL

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B60038.02Figure E-1

City of Lathrop


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IMP 16 1 of 5

IMP 16 – Fat, Oil & Grease Control

Responsible Person: Investigation/Documentation: Pretreatment Coordinator

Enforcement: Director of Public Works

City Manager

Legal Services: City Attorney

Frequency: Annual

Activity: Monitor Maintenance of FOG Interceptors & Traps

Inspect FOG interceptors and traps for grease overload, failure to separate FOG from

wastewater, excessive buildup of food wastes, and FOG pass through. Inspect FOG interceptor

and trap maintenance records.

Background:

Food Preparation Facilities include Restaurants, Cafeterias (hospitals, nursing homes, schools, etc.)

catering services, bakeries, and other facilities that prepare meals. Most of these facilities are

required to install and maintain FOG interceptors or traps. FOG interceptor. The requirement to

install an interceptor is a function of the building codes and administered through the issuance of a

building permit and inspections conducted by the City building inspectors. Once the interceptor has

been installed, the owner/operator is required to perform routine maintenance of the interceptor. It is

the function of the Pretreatment Coordinator and other designated City inspectors, such as, a Code

Enforcement Officer, to verify sufficient maintenance is being conducted to prevent carryover or

pass through of FOG from the interceptor.

Definitions and Descriptions:

FOG means Fats, Oils, and Grease.

FOG Interceptors are installed below ground and may be made up of one, two, or three chambers.

Each chamber will have a cleanout (manhole cover) that can be easily removed for

inspection and cleaning. Interceptors are usually cleaned by a commercial Grease

Trap Cleaning Service using a vacuum pump to remove the entire contents of the

interceptor and then fresh water to washdown the sides of the interceptor.

FOG Traps are small units installed under the sinks in the facility. Traps are usually hand cleaned.

The waste from the trap is collected in a drum. The drum is then collected by a

commercial Waste Disposal Operator.

Waste Grease refers to greases and oils that are manually collected in the facility to prevent it from

entering the FOG Interceptor/trap or the sewer system. Waste Grease is usually stored

IMP 16 2 of 5

in a labeled tank above ground outside the facility. Waste Grease is usually collected

by a commercial waste grease recycler.

Garbage Disposals/Food Grinders refers to grinding units that shred and grind waste food that is

discharged to the sewer system. These units should not discharge to the FOG

Interceptor/Trap. Excessive build up of waste food will interfere with the separation

of the FOG from the water wastestream.

Automatic Dishwashers discharge wastewater that is significantly hotter than hand wash dishwater.

Typically, Automatic Dishwashers should not discharge to a FOG Interceptor/Trap

unless the interceptor/trap is specifically designed to detain the wash water long

enough for the discharged wastewater to cool to allow the FOG to separate from the

wastestream. Two and three compartment interceptors would be needed to facilitate

the discharge of an Automatic Dishwasher.

Detention Time refers to the length of time wastewater is held in the interceptor. Detention time is a

function of discharge rate (gallons per minute) and the volume of the interceptor

(gallons). Interceptors must be appropriately sized to allow sufficient detention time

for the FOG to separate from the wastewater and float to the surface or for solids to

sink to the bottom. Interceptors with insufficient Detention Time will allow pass

through of FOG resulting in the buildup of FOG in the sewer collection lines.

Baseline Data includes the following: Business Name, Facility Address, Mailing Address, Phone

Number, Owner/Operator Name, Manager Name, Verification of Connection to City

Sewer, Verification of FOG Interceptor/trap Installed, Inceptor/trap capacity,

Interceptor/Trap Cleaning Frequency, Name, Address, and phone number of

Interceptor/Trap Cleaning (pumping) Service used, Name, Address, and phone

number of the FOG Waste Disposal Site used by the Cleaning Service. Baseline Data

is collected by requiring the facility to complete a FOG Control Questionnaire. This

questionnaire is authorized under Section 13.26.040 of the Sewer Use Ordinance. A

sample FOG Control Questionnaire is provided in Attachment A of this IMP.

Grease Trap Service Manifest refers to the document provided to the facility by the commercial

Grease Trap Cleaning Service at the time the interceptor is cleaned. It should contain

the Name of the Facility, the volume of grease/wastewater removed, the name,

address, and phone number of the cleaning service, the name and signature of the

cleaning service operator performing the work, the name and address of the disposal

site that will be used, and the date the service was performed. Section 13.26.160 E of

the Sewer Use Ordinance requires the food service facility to retain copies of these

manifest on-site and available for inspection.

Grease Trap Additives refers to any chemical, enzyme, or biological agent added to the FOG

Interceptor/trap to improve its operation, destroy the FOG molecules, emulsify the

FOG, or impact the operation of the interceptor in any way. Section 13.26.160 I of

IMP 16 3 of 5

the Sewer Use Ordinance prohibits the use of Grease Trap Additives.

FOG Control Inspection

FOG Control Inspections can be divided into two types: records inspection and interceptor/trap

inspection. Inspectors can use their best judgment whether to inspect the interceptor/trap, the records,

or both.

Records Inspection

The FOG Control Inspection Report form provides a checklist of the minimum information that

should be collected during the records inspection. The checklist items include: Business Name,

Physical Address, Mailing Address, Phone number, Manager’s Name, Name/Title of Business

Representative present during the inspection, Date of Last three (3) interceptor cleaning, Service

Company Name, Address; volume of waste removed; disposal site, address of disposal site.

If the business using a trap, review the in-house cleaning log; who performed the cleaning, date of

the last three (3) cleanings, waste disposal record, volume of waste removed, disposal practices.

Physical Inspection

The FOG Control Inspection Report form provided a checklist for the minimum information that

should be collected during the physical inspection. Note that the section of the report form that

contains the business information is completed for both a records inspection and physical inspection.

Additional information that should be included in the physical inspections include: Operator knew

where the interceptor/trap was located; access was easily acquired to interceptor; a grease buildup

was present but not excessive; food waste was/was not present; flow is/is not restricted through

interceptor; physical damage is not visible; no evidence of recent overflows from interceptor; drain

screens used in sinks; food grinders/garbage disposals used and are/ are not connected to interceptor;

kitchen cleanliness (excellent, good, fair, poor); interceptor additives are/are not used; waste grease

is/is not collected for recycling; area around waste grease collection tank is/is not clean.

Overflow Response

When responding to a report of a sewer overflow caused by an Interceptor, the inspector should

conduct both the records and physical inspection. In addition, the Overflow section of the FOG

Control Inspection Report form should be completed. Information in this section of the report would

include a description of the overflow site; were other businesses impacted by the overflow; did the

overflow reach a storm drain or receiving stream, when did the over flow start and stop,

approximately how much wastewater overflowed; corrective actions taken, preventative actions

taken.

IMP 16 4 of 5

Enforcement

Enforcement should be appropriate to level of the problems created by the operator not taking proper

actions. The following are examples of the appropriate action level for typical situations:

Compliance Issue Enforcement Action

Operator fails to retain maintenance records -verbal notification of record retention

requirements;

- follow up inspection in 3 months.

Maintenance records are incomplete -verbal notification of record retention

requirements;


Maintenance record indicates that only partial

pumping of trap is be conducted (pumped

volume is less than interceptor capacity)

-verbal notification of record retention

requirements;

- follow up inspection in 3 months

Operator applies grease trap additives to

interceptor

-verbal notification of record retention

requirements;


FOG build up in sewer collection lines tracked

to user service line; maintenance record

indicates reasonable cleaning frequency

-verbal request to pump and clean interceptor

and to visually inspect interceptor for

damage to inlet, weirs, and outlets

-follow up inspection in 1 to 2 weeks

FOG build up in sewer collection lines tracked

to user service line; maintenance record

indicates inappropriate cleaning frequency


within 48 hours and to visually inspect

interceptor for damage to inlet, weirs, and

outlets.

-follow up inspection within 72 hours

Inspection of interceptor indicates a lack of

pumping by an excessive buildup of grease

(greater than 12 to 14 inches of floatable grease

collected)


within 1 week and to visually inspect

interceptor for damage to inlet, weirs, and

outlets.

-follow up inspection within 2 to 3 weeks

Sanitary Sewer Overflow caused by grease

blockage traced to food service facility; records

inspection indicate lack of pumping; physical

inspection indicates interceptor in need of

pumping.

-verbal notification of overflow;

-verbal mandatory cleaning within 24 hours;

-written notification sent within 24 hours to

confirm notice of overflow and mandatory

cleaning;

-follow up inspection within 24 hours

Waste Grease collection tank is allowed to

overflow/spilling of waste grease around

collection tank allowing grease to enter

stormwater drains

-verbal notification with order to clean up area

and to resolve spillage and overflow;

-follow up inspection in 24 to 48 hours

IMP 16 5 of 5

Escalation of Enforcement Actions

In most cases, the enforcement actions is a cooperative effort to inform the user of the City Codes,

what constitutes proper maintenance; proper disposal of wastes; record keeping requirements; and

what to look for within the interceptor to make sure it is in good working order. However, once the

initial enforcement action has been taken and the user fails to perform the required actions or is a

repeat offender, the enforcement actions must be escalated. All escalated enforcement actions must

be in writing and must be signed by the City Public Works Director. Escalated enforcement actions

should be appropriate for the severity of the problem created. Escalated enforcement actions

available for the city include, but are not limited to the following:

1. Mandatory Pumping Frequency;

2. Resizing and Replacement of Interceptor;

3. Cost recovery for spill clean up and collection line cleaning;

4. Assessment of Administrative Fines;

5. Suspension of Water/Sewer Services

The City should consider all enforcement options and apply the appropriate action based on the

severity of the problem created by the operator’s lack of maintenance. In most cases education of the

operator is more effective than a heavy handed enforcement policy. Administrative Fines and Cost

Recovery should not be assessed at levels that make it more economical to violate the ordinance than

to perform the appropriate maintenance.

City Liability for Sewer Overflows

Notwithstanding the NPDES and State compliance issues concerning Sanitary Sewer Overflows, the

City has financial liabilities for sewer overflows that result in the damage to private property. A

sewer overflow into a business or residence, may result is extensive repair bills when drywalls,

carpet and flooring must be replaced. If the sewer overflow is due to a grease blockage traced to a

restaurant or food preparation facility, that facility may be held liable for the damages. However, the

City must show evidence (documentation) that the City has implemented a program to reduce or

eliminate sewer overflows due to grease blockage if the City is not to be held liable for property

damages. Therefore, it is important to implement and enforce the FOG Control program, uniformly

and consistently to all food service providers.

When a sewer overflows, it is usually the result of inappropriate materials in the sewer system. Please Help the City Pre-vent Sewer Back-ups and Overflows! Have you ever experienced a sanitary sewer back-up or overflow? Luckily, most sewer back-ups and overflows can be prevented with a progressive preventive maintenance program. All of us can help

to prevent them by wisely using the City Of Lathrop's sanitary sewer system. The City is "recruiting" customer partners who are willing to join our efforts to prevent sewer back-ups and overflows. Sewer back-ups and overflows are frequently caused by improper materials such as fats, oils and grease being placed into the sewer system by the City's customers. Since fats, oils and grease are lighter than water, they tend to accumu-late at the top and sides of sewer pipes

and can build up until a blockage occurs. If a blockage happens, the sewer backs up or overflows resulting in property and environmental damage. The City of Lathrop's Sewer Use Ordinance requires that restaurants should install and maintain grease traps and/or interceptors to prevent grease from entering the sewer system. However, there are many more res-idential kitchens than there are res-taurants in Lathrop. By reducing the amount of fats, oils and grease that enter

the sewer system from homes, you can help to protect the environment by pre-venting sewer back-ups and over-flows. Sanitary sewer systems are designed to handle three things: used water, human body waste, and toilet paper. You can do some simple things that will help the City protect water quality and maintain the sewer system in Lathrop.

Preventing Sewer Back-Ups & Sewer Overflows

What To Do:

• Collect grease in a container and dispose of it in the garbage.

• Place food scraps in waste containers or garbage bags for disposal with solid waste, or start a compost pile.

• Place a wastebasket in the bathroom to dispose of solid waste. Disposable diapers, condoms and personal

hygiene products do not belong in the sewer system.

• These suggestions can save you money too! Most sewer back-ups occur between the house and the City's sewer main, where the property owner is responsible for correcting the problem. Avoiding

blockages means avoiding plumbing bills. When the blockage occurs in the City's sewer main, the City will correct the problem. Please call the Public Works Department at (209) 941-7430, to report a sewer back-up or overflow. After hours call the after-hours emergency number, (209) 992-0028.

Phone: (209) 941-7430

Fax:: (209) 941-7449

E-mail:: [email protected]

PUBLIC WORKS DEPARTMENT

What Not To Do:

• Pour grease, fats and oils from cooking down the drain.

• Use the toilet as a wastebasket.

• Use the sewer as a means to dispose of

food scraps.

APPENDIX F – Element 8 (System Evaluation and Capacity Assurance Plan)

City of Lathrop Sewer System Management Plan F-1

APPENDIX F – Element 8 (System Evaluation and Capacity Assurance Plan) Supporting Documents

1. Table F-1. Existing Wastewater Flow by Development Area

2. Table F-2. Projected Wastewater Flow by Development Area

3. Table F-3 Peak Wet Weather Flow at Pump Stations.

4. Table F-4. Recommended Collection System Improvement Projects

5. Table F-5. Summary of Capital Improvement Projects

6. Figure F-1. Overview of Capital Improvement Projects

Appendix F - Element 8 (System Evaluation and Capacity Assurance Plan)

Table F-1Existing Wastewater Flow by Development Area

Existing Development Wastewater Flow Existing Wastewater

Land Use Designation Built After 2013 Units Factor Generation (gpd)Central Lathrop

2013 Central Lathrop ADWF (a) 6,19710% Safety Factor 620

School/Institutional 12 ac 245 gpd/ac 2,889Total Estimated Wastewater Flow for Existing Development Built After 2013 2,889

Total Existing Central Lathrop ADWF 9,705Mossdale

2013 Mossdale ADWF (b) 293,25610% Safety Factor 29,326

Low Density Residential 136 du 245 gpd/du 33,320Medium Density Residential 21 du 170 gpd/du 3,570Parks 4.8 ac 55 gpd/ac 264

Total Estimated Wastewater Flow for Existing Development Built After 2013 37,154Total Existing Mossdale ADWF 359,736

River Islands2013 River Islands ADWF 0

10% Safety Factor 0Low Density Residential 449 du 245 gpd/du 110,005Commercial 4.7 ac 590 gpd/ac 2,773Schools 30 ac 245 gpd/ac 7,350Parks and Landscaping Parcels 12 ac 55 gpd/ac 660

Total Estimated Wastewater Flow for Existing Development Built After 2013 120,788 Total Existing River Islands ADWF 120,788

South Lathrop2013 South Lathrop ADWF 0

10% Safety Factor 0Total Estimated Wastewater Flow for Existing Development Built After 2013 0

Total Existing South Lathrop ADWF 0Lathrop Gateway

2013 Lathrop Gateway ADWF 010% Safety Factor 0

Total Estimated Wastewater Flow for Existing Development Built After 2013 0 Total Existing Lathrop Gateway ADWF 0

Crossroads2013 Crossroads ADWF 108,372

10% Safety Factor 10,837Industrial 11 ac 355 gpd/ac 3,912

Total Estimated Wastewater Flow for Existing Development Built After 2013 3,912 Total Existing Crossroads ADWF 123,121

Historic Lathrop and Other Development Areas2013 Historic Lathrop ADWF 949,856

10% Safety Factor 94,986Low Density Residential 27 du 245 gpd/du 6,615Commercial 43.8 ac 590 gpd/ac 25,842Parks 4.8 ac 55 gpd/ac 264

Total Estimated Wastewater Flow for Existing Development Built After 2013 32,721 Total Existing Historic Lathrop ADWF 1,077,563

TOTAL EXISTING ADWF 1,690,913EXISTING ADWF AT CTF 613,350

EXISTING ADWF AT MWQCF 1,077,563

Notes:(a)

(b)

Because historical wastewater flow data from the Central Lathrop area are not available, 2013 Central Lathrop ADWF is estimated using the wastewater flow factor for the Lathrop High School, which was the only facility that was sewered in Central Lathrop during 2013. The 2013 Mossdale ADWF is historical flow measured at the Mossdale Pump Station subtracted by estimated flow for the Central Lathrop area.



Table F-2Projected Wastewater Flow by Development Area

Wastewater Projected New Wastewater Flow (gpd) (a)Land Use Designation Flow Factor 2020 2025 2030 2035 2040 Buildout

Central LathropLow Density Residential 245 gpd/du 147,000 266,315 489,020 489,020 489,020 1,494,010Medium Density Residential 170 gpd/du 0 40,630 40,630 40,630 40,630 40,630High Density Residential 170 gpd/du 0 46,580 46,580 46,580 46,580 77,010Commercial 590 gpd/ac 11,210 22,715 34,515 47,141 70,151 164,315Parks 55 gpd/ac 473 1,947 3,674 3,674 3,674 6,325Schools 245 gpd/ac 0 4,410 4,410 4,410 4,410 13,377Public Landscaping 55 gpd/ac 1,188 1,309 1,997 1,997 1,997 2,549

New Central Lathrop ADWF 159,871 383,906 620,826 633,452 656,462 1,798,216Existing Central Lathrop ADWF 9,705 9,705 9,705 9,705 9,705 9,705

Projected Central Lathrop ADWF 169,576 393,611 630,531 643,157 666,167 1,807,922Mossdale - All Developments

Low Density Residential 245 gpd/du 9,065 9,065 25,235 25,235 25,235 186,445Medium Density Residential 170 gpd/du 0 10,880 10,880 23,460 23,460 23,460High Density Residential 170 gpd/du 45,220 45,220 45,220 58,480 71,740 71,740Commercial 590 gpd/ac 0 8,201 8,201 20,886 28,556 28,556Parks 55 gpd/ac 0 220 220 220 220 220Schools 245 gpd/ac 0 3,979 3,979 3,979 3,979 3,979

New Mossdale ADWF 54,285 77,565 93,735 132,260 153,190 314,400Existing Mossdale ADWF 359,736 359,736 359,736 359,736 359,736 359,736

Projected Mossdale ADWF 414,021 437,301 453,471 491,996 512,926 674,136River Islands

Low Density Residential 245 gpd/du 371,665 765,961 1,112,266 1,569,803 1,910,211 1,910,211Medium Density Residential 170 gpd/du 43,032 99,069 148,286 213,311 261,690 261,690High Density Residential 170 gpd/du 0 68,000 205,700 205,700 205,700 205,700Commercial 590 gpd/ac 5,900 35,400 88,500 147,500 188,800 188,800Golf Clubhouse 55 gpd/ac 0 0 0 0 0 0Schools 245 gpd/ac 2,695 8,330 22,295 24,990 27,685 27,685Animal Campus 245 gpd/ac 0 2,450 2,450 2,450 2,450 2,450Parks and Landscaping Parcels 55 gpd/ac 1,320 3,355 5,555 7,535 9,020 9,020

New River Islands ADWF 424,612 982,565 1,585,052 2,171,289 2,605,556 2,605,556Existing River Islands ADWF 120,788 120,788 120,788 120,788 120,788 120,788

Projected River Islands ADWF 545,400 1,103,353 1,705,840 2,292,077 2,726,344 2,726,344South Lathrop

Light Industrial / R&D Flex 355 gpd/ac 58,398 78,526 78,526 78,526 78,526 86,194Office Commercial 590 gpd/ac 0 5,168 5,168 5,168 5,168 5,168Open Space 55 gpd/ac 373 373 373 373 373 373Public Landscaping 55 gpd/ac 44 44 44 44 44 44

New South Lathrop ADWF 58,814 84,111 84,111 84,111 84,111 91,779Existing South Lathrop ADWF 0 0 0 0 0 0

Projected South Lathrop ADWF 58,814 84,111 84,111 84,111 84,111 91,779Lathrop Gateway

Light Industrial / R&D Flex 355 gpd/ac 0 0 0 0 59,498 59,498Office Commercial 590 gpd/ac 0 0 0 0 82,423 82,423Open Space 55 gpd/ac 0 0 0 0 88 88Public Landscaping 55 gpd/ac 0 0 0 0 0 0

New Lathrop Gateway ADWF 0 0 0 0 142,009 142,009Existing Lathrop Gateway ADWF 0 0 0 0 0 0

Projected Lathrop Gateway ADWF 0 0 0 0 142,009 142,009



Table F-2 (Continued)Projected Wastewater Flow by Development Area

IWRMP Projected New Wastewater Flow (gpd) (a)Land Use Designation Flow Factor 2020 2025 2030 2035 2040 Buildout

CrossroadsIndustrial 355 gpd/ac 22,365 23,075 23,075 23,075 31,240 31,240Commercial 590 gpd/ac 1,298 12,980 12,980 12,980 12,980 12,980

New Crossroads ADWF 23,663 36,055 36,055 36,055 44,220 44,220Existing Crossroads ADWF 123,121 123,121 123,121 123,121 123,121 123,121

Projected Crossroads ADWF 146,784 159,176 159,176 159,176 167,341 167,341Historic Lathrop and Other Development Areas

Low Density Residential 245 gpd/du 1,470 2,940 4,410 5,880 7,105 8,330Medium Density Residential 170 gpd/du 4,590 9,180 13,600 18,020 22,440 26,860High Density Residential 170 gpd/du 850 1,530 2,210 2,890 3,570 4,250Commercial 590 gpd/ac 8,260 23,942 28,662 33,382 38,102 53,153Industrial 355 gpd/ac 29,110 43,665 43,665 43,665 43,665 94,430Parks 55 gpd/ac 0 0 0 0 0 0Schools 245 gpd/ac 0 0 0 0 0 0California Natural Products (b) -- 71,689 161,300 161,300 161,300 161,300 161,300

New Historic Lathrop / Other ADWF 115,969 242,557 253,847 265,137 276,182 348,323Existing Historic Lathrop / Other ADWF 1,077,563 1,077,563 1,077,563 1,077,563 1,077,563 1,077,563

Projected Historic Lathrop / Other ADWF 1,193,532 1,320,120 1,331,410 1,342,700 1,353,745 1,425,886Sharpe Army Depot

Industrial -- 32,000 32,000 32,000 32,000 32,000 32,000New Sharpe Army Depot ADWF 32,000 32,000 32,000 32,000 32,000 32,000

Existing Sharpe Army Depot ADWF 0 0 0 0 0 0Projected Sharpe Army Depot ADWF 32,000 32,000 32,000 32,000 32,000 32,000

Existing Development to be Connected to City Sewer SystemCommercial 590 gpd/ac 6,549 6,549 6,549 6,549 6,549 6,549Industrial 355 gpd/ac 22,685 22,685 22,685 22,685 22,685 22,685Schools 245 gpd/ac 7,350 7,350 7,350 7,350 7,350 7,350

New ADWF 7,350 7,350 7,350 7,350 7,350 7,350Total Projected New ADWF 876,564 1,846,109 2,712,975 3,361,654 4,001,079 5,383,853

Existing ADWF 1,690,913 1,690,913 1,690,913 1,690,913 1,690,913 1,690,913TOTAL PROJECTED ADWF 2,567,477 3,537,022 4,403,888 5,052,567 5,691,992 7,074,766

PROJECTED ADWF AT CTF 1,334,595 2,177,552 3,033,128 3,670,517 4,298,897 5,609,530 PROJECTED ADWF AT MWQCF 1,232,882 1,359,470 1,370,760 1,382,050 1,393,095 1,465,236

Notes:(a)

(b) Existing ADWF from California Natural Products (CNP) in the Historic Lathrop area is estimated to be 38,700 gpd, based on the difference between 2013 ADWF at the McKinley PS and calculated ADWF for remaining parcels in the McKinley PS drainage area excluding CNP. Flows from CNP are projected to reach their allocated 200,000 gpd by 2025.

Projected residential wastewater generation calculated as the total number of projected residential dwelling units multiplied by the applicable wastewater flow factor (Table 8-1). Projected non-residential wastewater flow are calculated as the total projected acreage multiplied by the applicable wastewater flow factor (Table 8-1).



Table F-3Peak Wet Weather Flow at Pump Stations

Existing (2016) Near-Term Future (2025) Long-Term Future (2040) Selected BuildoutADWF (mgd)

Peaking Factor

PWWF (mgd)

ADWF (mgd)

Peaking Factor

PWWF (mgd)

ADWF (mgd)

Peaking Factor

PWWF (mgd)

ADWF (mgd)

Peaking Factor

PWWF (mgd)

MWQCF Collection SystemNorth Harlan LS (a) -- -- -- 0.046 5.7 0.263 0.056 5.5 0.308 0.056 5.5 0.308Stonebridge LS 0.206 3.7 0.758 0.210 3.6 0.764 0.210 3.6 0.764 0.210 3.6 0.764Woodfield LS 0.390 2.7 1.071 0.440 2.6 1.151 0.450 2.6 1.167 0.450 2.6 1.167Valley Crossing LS 0.008 6.5 0.055 0.008 6.5 0.055 0.008 6.5 0.055 0.008 6.5 0.055J Street LS 0.646 2.3 1.509 0.264 3.3 0.866 0.276 3.2 0.886 0.276 3.2 0.886Easy Court LS 0.095 4.9 0.462 0.095 4.9 0.465 0.095 4.9 0.465 0.095 4.9 0.465O Street PS 0.925 2.2 2.063 0.551 2.4 1.338 0.572 2.4 1.375 0.572 2.4 1.375McKinley Avenue PS 0.131 4.4 0.578 0.754 2.3 1.716 0.768 2.3 1.744 0.768 2.3 1.744Louise Avenue PS 0.003 6.6 0.019 -- -- -- -- -- -- -- -- --

Lathrop CTF Collection SystemCentral Lathrop Low Flow PS 0.015 6.3 0.096 -- -- -- -- -- -- -- -- --Central Lathrop PS (Future) -- -- -- 0.401 2.7 1.088 0.676 2.3 1.567 0.676 2.3 1.567Mossdale PS 0.481 2.5 1.218 0.550 2.4 1.336 0.627 2.4 1.474 0.627 2.4 1.474River Islands Interim PS 0.113 4.6 0.523 -- -- -- -- -- -- -- -- --River Islands Sewer PS (b) -- -- -- 1.105 2.2 2.444 2.738 2.2 6.025 2.738 2.2 6.02Crossroads PS 0.143 4.3 0.611 0.210 3.6 0.765 0.219 3.6 0.782 0.219 3.6 0.782South Lathrop PS -- -- -- 0.088 5.0 0.439 0.088 5.0 0.439 0.095 4.9 0.462Lathrop Gateway PS -- -- -- -- -- -- 0.15 4.2 0.63 0.15 4.2 0.629

Notes:(a) North Harlan Pump Station is an existing private pump station and that will be upgraded and converted to a public pump station by 2018.(b) Wastewater from River Islands is conveyed through an interim pump station and will be redirected to a permanent pump station in its vicinity.

Lift Station or Pump Station



Table F-4Recommended Collection System Improvement Projects

Improvement Type

Description Quantity Unit Cost Construction OPC (a)

Project WW-1: Stonebridge Gravity Main Replacement and Parallel Force Main ProjectGravity Main Install new 10" gravity main 1,140 LF $ 180 $ 205,200 Gravity Main Install new 12" gravity main 1,230 LF $ 216 $ 265,680 Force Main Install new 6" parallel force main 1,800 LF $ 90 $ 162,000 Laterals Replace sewer laterals 35 ls $ 2,000 $ 70,000 Manhole Rehabilitate manholes 15 ls $ 3,000 $ 45,000

Construction Contingency (25%) $ 186,970 Construction OPC $ 934,850

Engineering and Administration Costs (35%) $ 261,758 Total Project OPC $ 1,200,000

Project WW-2A: Woodfield West Deficiency Project - Alternative A

Gravity MainInstall new 18" gravity main from Jasper St to Long Barn Dr

3,760 LF $ 324 $ 1,218,240

Laterals Replace sewer laterals 104 ls $ 2,000 $ 208,000 Manhole Rehabilitate manholes 18 ls $ 3,000 $ 54,000

Construction Contingency (25%) $ 370,060 Construction OPC $ 1,850,300


Project WW-2B: Woodfield West Deficiency Project - Alternative BForce Main Jack & Bore new 8" force main through I-5 500 LF $ 1,000 $ 500,000 Force Main Install new 8" force main to Dos Reis Road 5,550 LF $ 120 $ 666,000 Pump Station Stonebridge PS upgrade 1 ls $ 200,000 $ 200,000



Project WW-3: Woodfield Pump Station UpgradePump Station Woodfield PS upgrade 1 ls $ 200,000 $ 200,000


Engineering and Administration Costs (35%) $ 70,000 Total Project OPC $ 320,000

Project WW-4: Woodfield East Gravity Main Replacement Project

Gravity MainInstall new 10" gravity main from Pinewood Drive to Long Barn Dr

1,920 LF $ 180 $ 345,600

Laterals Replace sewer laterals 56 ls $ 2,000 $ 112,000 Manholes Rehabilitate manholes 8 ls $ 3,000 $ 24,000





Table F-4 (Continued)Recommended Collection System Improvement Projects

Improvement Type


Project WW-5: J Street Gravity Main Replacement ProjectGravity Main Install new 8" gravity main on Cotton Drive 740 LF $ 144 $ 106,560 Gravity Main Install new 10" gravity main on Cambridge Drive 1,420 LF $ 180 $ 255,600 Gravity Main Install new 12" gravity main on Cambridge Drive 50 LF $ 216 $ 10,800 Gravity Main Install new 15" gravity main on J Street 850 LF $ 270 $ 229,500 Gravity Main Install new 18" gravity main on J Street 280 LF $ 324 $ 90,720 Laterals Replace sewer laterals 50 ls $ 2,000 $ 100,000 Manholes Rehabilitate manholes 12 ls $ 3,000 $ 36,000



Project WW-6: Easy Court / O Street Gravity Main Replacement ProjectGravity Main Install new 8" gravity main on O Street 580 LF $ 144 $ 83,520 Gravity Main Install new 10" gravity main on O Street 1,660 LF $ 180 $ 298,800 Gravity Main Install new 12" gravity main on O Street 1,460 LF $ 216 $ 315,360 Gravity Main Install new 15" gravity main on O Street 130 LF $ 270 $ 35,100 Gravity Main Install new 18" gravity main on O Street 850 LF $ 324 $ 275,400 Laterals Replace sewer laterals 97 ls $ 2,000 $ 194,000 Laterals Reconnect back alley laterals to replacement sewer 3 ls $ 4,000 $ 12,000 Manholes Rehabilitate manholes 20 ls $ 3,000 $ 60,000



Project WW-7: Crossroads Gravity Main Replacement ProjectGravity Main Install new 12" gravity main on Murphy Parkway 1,690 LF $ 240 $ 405,600 Gravity Main Install new 15" gravity main on Nestle Way 1,730 LF $ 330 $ 570,900 Laterals Replace sewer laterals 7 ls $ 2,500 $ 17,500 Manholes Rehabilitate manholes 11 ls $ 3,000 $ 33,000





Table F-4 (Continued)Recommended Collection System Improvement Projects

Improvement Type


Project WW-8: Golden Spike Trail Gravity Main Replacement ProjectGravity Main Install new 15" gravity main on Golden Spike Trail 1,380 LF $ 270 $ 372,600 Laterals Replace sewer laterals 1 ls $ 2,250 $ 2,250 Manholes Rehabilitate manholes 7 ls $ 3,000 $ 21,000



Project WW-9: McKee Boulevard Gravity Main Replacement ProjectGravity Main Install new 10" gravity main on McKee Boulevard 200 LF $ 180 $ 36,000 Gravity Main Install new 12" gravity main on McKee Boulevard 200 LF $ 216 $ 43,200 Gravity Main Install new 15" gravity main on McKee Boulevard 460 LF $ 300 $ 138,000 Laterals Replace sewer laterals 5 ls $ 2,250 $ 11,250 Manholes Rehabilitate manholes 6 ls $ 3,000 $ 18,000



Project WW-10: Other Gravity Main ReplacementsGravity Main Install new 8" gravity main 410 LF $ 144 $ 59,040 Gravity Main Install new 10" gravity main 2,780 LF $ 180 $ 500,400 Gravity Main Install new 12" gravity main 680 LF $ 216 $ 146,880 Gravity Main Install new 15" gravity main 470 LF $ 270 $ 126,900 Laterals Replace sewer laterals 52 ls $ 2,000 $ 104,000 Manholes Rehabilitate manholes 38 ls $ 3,000 $ 114,000



TOTAL COLLECTION SYSTEM CIP COST (ALTERNATIVE A) $ 12,370,000 TOTAL COLLECTION SYSTEM CIP COST (ALTERNATIVE B) $ 12,190,000

Notes:(a) Costs shown are presented in September 2017 dollars based on an ENR CCI of 10,823 (20-city average).



Table F-5Summary of Capital Improvement Projects

Project Number

Project Timeframe

Addresses Modeled

Surcharging in Existing Scenario

Total Project OPC (a)

WWT-1 Lathrop CTP Expansion to 5.5 MGD Long-Term Future -- $ 45,000,000 (c)

WW-1 Stonebridge Gravity Main Replacement and Parallel Force Main Project Existing (b) Yes $ 1,200,000 WW-2A Woodfield West Deficiency Project - Alternative A Existing (b) No $ 2,370,000 WW-2B Woodfield West Deficiency Project - Alternative B Existing (b) No $ 2,190,000 WW-3 Woodfield Pump Station Upgrade Existing (b) No $ 320,000 WW-4 Woodfield East Gravity Main Replacement Project Existing No $ 770,000 WW-5 J Street Gravity Main Replacement Project Existing (b) Yes $ 1,330,000 WW-6 Easy Court / O Street Gravity Main Replacement Project Existing (b) Yes $ 2,040,000 WW-7 Crossroads Gravity Main Replacement Project Existing (b) No $ 1,640,000 WW-8 Golden Spike Trail Gravity Main Replacement Project Existing (b) No $ 630,000 WW-9 McKee Boulevard Gravity Main Replacement Project Existing No $ 390,000

WW-10 Other Gravity Main Replacements Existing (b) No $ 1,680,000 $ 12,190,000 - $ 12,370,000

WW-11 Installation of Permanent Flow Meters and Flow Monitoring -- -- $ 100,000 $ 57,290,000 - $ 57,470,000

Notes:(a) Costs shown are presented in September 2017 dollars based on an ENR CCI of 10,823 (20-city average).(b) Project addresses existing deficiencies, however future development influences recommended pipe or pump sizes to be installed.(c) Total project OPC consists of construction OPC developed based on a unit cost of $9 per gallon additional ADWF capacity, 25% construction

contingency, and 35% engineering and administration costs.

Treatment Facility Improvement Projects

Collection System Improvement Projects

Collection System CIP Cost SubtotalMiscellaneous Collection System Projects

TOTAL CIP COST


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WW-1: Stonebridge Gravity MainReplacement and ParallelForce Main (See Note 3)

WW-4: Woodfield EastGravity Main Replacement

WW-6: Easy Court/O StreetGravity Main Replacement

WW-7: Crossroads GravityMain Replacement

WW-8: Golden SpikeTrail Gravity

Main Replacement

WW-9: Mckee BoulevardGravity Main Replacement

WW-5: J StreetGravity Main

Replacement

WW-2A: Woodfield WestDeficiency Project - Alternative A

WW-3: WoodfieldPS Upgrade

WW-2B: Woodfield West Deficiency Project

Alternative B (See Note 3)

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AbbreviationsCTFMWQCFWWTF

Notes1. All locations are approximate.2. The Stonebridge Lift Station Upgrade is a part of the Woodfield West Deficiency Project- Alternative B, not a part of the Stonebridge Gravity Main Replacement and Parallel Force Main Project.


Legend

DRAFT

± 0 2,500 5,000(Scale in Feet)

Recommended Collection SystemImprovement Projects


B60038.02Figure F-1

City of Lathrop

= Consolidated Treatment Facility= Manteca Water Quality Control Facility= wastewater treatment facility

Force Main

Approximate Area of WWTF[Ú

Gravity MainDiamter of Replacement Sewer

Diameter of Parallel Force Main


Sphere of Influence

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APPENDIX G – Element 9 (Monitoring, Measurement and Program Modifications)

City of Lathrop Sewer System Management Plan G-1

APPENDIX G – Element 9 (Monitoring, Measurement and Program Modifications) Supporting Documents

1. SSMP Monitoring Tracking Sheet

2. SSMP Change Log



CITY OF LATHROP

SEWER SYSTEM MANAGEMENT PLAN

MONITORING TRACKING SHEET

2013 2014 2015 2016 2017

SSO Summary

Total Number of SSOs 5 1 1 5 1

Total Volume of SSOs 2,570 100 100 2,360 5

Vol of SSO Contained and/or Returned 2,570 100 100 2,360 5

Vol of SSO Reached Surface Water 0 0 0 0 0

% of SSO Volume Contained and/or Returned 100% 100% 100% 100% 100%

% of SSO Volume Reaching Waters 0% 0% 0% 0% 0%

SSO by Cause

Grease Deposition (FOG) 0 1 1 4 0

Debris 3 0 0 0 1

Capacity/Hydraulic Deficiency 0 0 0 0 0

Pump Station Failure 1 0 0 0 0

Other 1 0 0 1 0

SSO by Location

Gravity Main SSO 4 1 1 5 1

Pump Station SSO 1 0 0 0 0

Force Main SSO 0 0 0 0 0

Maintenance Summary

Length of Pipe Cleaned -- -- 10.8 15.7 7.9

Length of Pipe CCTV'ed -- -- -- 5 0.5



CITY OF LATHROP

SEWER SYSTEM MANAGEMENT PLAN

CHANGE LOG

Date SSMP

Element

/Section

Description of Change/Revision Made Authorized

By:

Feb 2018 Introduction • Updated system description and statistics in the

City Service Area and Sewer System section.

G. Gibson

Feb 2018 1 • Updated goals and condensed the number of

goals.

G. Gibson

Feb 2018 2 • Updated the organization discussion in

Section 2.3.

• Updated organization chart, contact information,

and descriptions of general responsibilities in

Appendix A.

• Added Table A-2, list of staff responsible for

SSMP elements.

• Updated SSO chain of communication and

moved to the OERP in Appendix D.

• Added City Manager, CDPH, CDF&G, SSJID to

Table 2-1, officials receiving immediate

notification of SSO per the OERP. Revised the

circumstance for immediate notification to Cal

OES to be consistent with the MRP

G. Gibson

Feb 2018 3 • Updated the Sewer Use Ordinance ERP and the

FOG ERP.

• Removed code sections from appendix and

included link to City’s website.

• Added the City’s CPC adoption in the Municipal

Code discussion in Section 3.3. Updated

“Prevention of Illicit Discharges” and

“Enforcement Measures” discussions.

G. Gibson

Feb 2018 4 • Updated the collection system map discussion to

reflect current City practices using a GIS

database in Section 4.3.

• Updated O&M activities and confirmed

maintenance frequencies in Section 4.4.

• Added a description of the SEMS asset

management software to Section 4.5 and added a

link to City’s five-year CIP.

• Added details regarding training programs in the

training discussion in Section 4.6.

G. Gibson



Date SSMP

Element

/Section


By:

Feb 2018 5 • Updated information regarding the 2014 Design

and Construction Standards update and provided

a link to the 2014 Design and Construction

Standards. Removed Appendix D.

• Updated description regarding the role of the

Senior Construction Inspector.

G. Gibson

Feb 2018 6 • Updated the SSO categories in the OERP

discussion to match the OERP attached and the

MRP.

G. Gibson

Feb 2018 OERP • Made editorial changes to the OERP.

• Added description of responses to private lateral

blockages.

• Added discussion of responses to overflows at

the treatment plant.

• Edited description of Category 1 SSO to be

consistent with the MRP.

• Added details regarding notification to internal

managers to be consistent with Table 2-1.

• Added a SSO Reporting Chain of

Communication flow chart.

• Updated OERP contact information.

G. Gibson

Feb 2018 7 • Updated Table E-1, list of food service facilities

in Lathrop and added Figure E-1, location of

food service facilities in Lathrop.

• Removed FOG program sample forms from

Appendix E as they are attached in the FOG

ERP in Appendix B.

• Added a FOG disposal plan discussion in

Section 7.3.

• Added information on FOG program education

conducted during inspection and enforcement.

G. Gibson

Feb 2018 8 • Updated Element 8 to reflect findings from the

City’s recent (2018) Wastewater System Master

Plan update and included additional tables and

figures in Appendix F.

G. Gibson

Feb 2018 9 • Updated SSMP monitoring parameters and the

monitoring template in Appendix G.

G. Gibson

Feb 2018 10 • Added a template SSMP program audit form in

Appendix H.

G. Gibson



Date SSMP

Element

/Section


By:

Jun 2016 2 • Updated staff contact information and

organization chart in Appendix A.

G. Gibson

Jun 2016 6 • Updated SSO contact information. G. Gibson

Jun 2013 2 • Updated staff contact information and

organization chart in Appendix A.

G. Gibson

Jun 2013 6 • Updated SSO contact information. G. Gibson

APPENDIX H – Element 10 (SSMP Program Audits)

City of Lathrop Sewer System Management Plan H-1

APPENDIX H – Element 10 (SSMP Program Audits) Supporting Documents

1. Blank SSMP Program Audit Form

2. Completed SSMP Program Audits



City of Lathrop

Sewer System Management Plan Audit Report

_____ through _____

Date:

Prepared by:

Reviewed by:

The purpose of the SSMP Audit is to evaluate the effectiveness of the City of Lathrop’s (City’s)

SSMP and to identify any need for improvement.

Directions: Please check YES or NO for each question. If No is answered to any question,

describe the updates/changes and the timeline to complete those changes.

INTRODUCTION

A. Is the current system description complete and up-to-date? Are

infrastructure statistics current and complete?

YES NO

Discussion/Deficiencies/Corrective Actions:

ELEMENT 1 – GOALS

A. Are the goals stated in the SSMP still appropriate and current? YES NO


ELEMENT 2 – ORGANIZATION

A. Is the Organization Chart in Figure A-1 of the SSMP current?? YES NO

B. Are the position descriptions an accurate portrayal of staff

responsibilities?

YES NO

C. Is the chain of communication for reporting and responding to SSOs

accurate and up-to-date?

YES NO

D. Is the contact information in Table A-1 current? YES NO

E. Is the List of City Staff Responsible for SSMP in Table A-2 current? YES NO


ELEMENT 3 – LEGAL AUTHORITY

Does the SSMP contain current references to the Lathrop Municipal Code documenting the

City’s legal authority to:



A. Prevent illicit discharges? YES NO

B. Require proper design and construction of sewers and connections? YES NO

C. Ensure access for maintenance, inspection, or repairs for portions of the

lateral owned or maintained by the City?

YES NO

D. Limit discharges of fats, oils, and grease? YES NO

E. Enforce any violation of its sewer ordinances? YES NO

F. Were any changes or modifications made in the past two years (this

audit period) to City Sewer Ordinances, Regulations, or standards?

(discuss below)


ELEMENT 4 – OPERATIONS AND MAINTENANCE

Collection System Maps

A. Does the SSMP reference the current process and procedures for

maintaining the City’s sewer system maps?

YES NO

B. Are the City’s collection system maps complete, up-to-date, and

sufficiently detailed?

YES NO

Preventative Maintenance

C. Does the SSMP describe current preventative maintenance activities

and the system for prioritizing the cleaning of sewer lines?

YES NO

D. Are the City’s preventive maintenance activities sufficient and effective

in reducing and preventing SSOs and blockages?

YES NO

Rehabilitation and Replacement Plan

E. Is there an ongoing condition assessment program sufficient to rank the

condition of sewer pipes and schedule rehabilitation? Are the current

components of this program documented in the SSMP?

YES NO

F. Are scheduled inspections and the condition assessment system

effective in identifying, prioritizing, and addressing deficiencies?

YES NO

G. Does the rehabilitation and replacement plan include a capital

improvement plan that addresses proper management and protection of

the infrastructure assets? Does the plan include a time schedule for

implementing the short and long-term plans plus a schedule for

developing the funds needed for the capital improvement plan?

YES NO

Training

H. Does the SSMP document current training expectations and programs? YES NO

I. Do supervisors believe their staff are sufficiently trained? YES NO

J. Are the training records current? YES NO

Equipment and Replacement Part Inventories



K. Does the SSMP list the major equipment currently used in the operation

and maintenance of the collection system?

YES NO

L. Are contingency equipment and replacement parts sufficient to respond

to emergencies and properly conduct regular maintenance?

YES NO


ELEMENT 5 – DESIGN AND PERFORMANCE PROVISIONS

A. Does the SSMP reference current design and construction standards for

the installation of new sanitary sewer systems, pump stations and other

appurtenances and for the rehabilitation and repair of existing sanitary

sewer systems?

YES NO

B. Does the SSMP document current procedures and standards for

inspecting and testing the installation of new sewers, pumps, and other

appurtenances and the rehabilitation and repair of existing sewer lines?

YES NO


ELEMENT 6 – OVERFLOW EMERGENCY RESPOSNE PLAN

A. Does the City’s Overflow Emergency Response Plan (OERP) contain

proper notification procedures so that the primary responders and

regulatory agencies are informed of all sanitary sewer overflows

(SSOs) as required by the WDR and MRP?

YES NO

B. Does the OERP have a program to ensure an appropriate response to all

overflows?

YES NO

C. Does the OERP contain procedures to ensure prompt notification to

appropriate regulatory agencies and other potentially affected entities of

all SSOs that potentially affect public health or reach waters of the State

in accordance with the MRP? Does the SSMP identify the officials who

will receive immediate notification of such SSOs?

YES NO

D. Are staff and contractor personnel aware of and appropriately trained

on the procedures of the OERP?

YES NO

E. Does the OERP contain procedures to address emergency operations

such as traffic and crowd control and other necessary response

activities?

YES NO

F. Does the OERP ensure that all reasonable steps are taken to contain and

prevent the discharge of untreated and partially treated wastewater to

waters of the United States and to minimize or correct any adverse

impact on the environment resulting from SSOs, including such

accelerated or additional monitoring as may be necessary to determine

the nature and impact of the discharge?

YES NO



G. Considering SSO performance data, is the OERP effective in handling

SSOs in order to safeguard public health and the environment?

YES NO

H. Is the Water Quality Monitoring Plan current and has it been trained on

and practiced by staff that would be involved in a SSO of large

volume?

YES NO

I. If applicable, was sampling performed within 48 hours for all SSOs

greater than 50,000 gallons and was a Technical Report prepared and

filed on the CIWQS website?

YES NO


ELEMENT 7 – FATS, OILS, AND GREASE (FOG) CONTROL PROGRAM

A. Does the FOG Control Program include a description of public

education outreach efforts that promote proper handling and disposal of

FOG?

YES NO

B. Does the FOG program include a plan for the disposal of FOG

generated within the sewer system service area?

YES NO

C. Does the City have sufficient legal authority to prohibit discharges to

the system and identify measures to prevent SSOs and blockages

caused by FOG?

YES NO

D. Are there requirements to install grease removal devices (such as traps

or interceptors), best management practices (BMP) requirements,

record keeping, maintenance requirements and reporting requirements

established in the City’s FOG Control Program?

YES NO

E. Does the City have authority to inspect grease producing facilities and

have sufficient staff to inspect and enforce the FOG ordinance?

YES NO

F. Does the FOG control program identify sections of the collection

system subject to FOG blockages, establish a cleaning schedule and

address source control measures to minimize these blockages?

YES NO

G. Does the FOG control program implement source control measures for

all sources of FOG discharged to the collection system?

YES NO

H. Is the current FOG program effective in minimizing blockages of sewer

lines resulting from discharges of FOG to the system?

YES NO


ELEMENT 8 – SYSTEM EVALUATION AND CAPACITY ASSURANCE PLAN

A. Does the System Evaluation and Capacity Assurance Plan evaluate

hydraulic deficiencies in the system and provide estimates of peak

YES NO



flows associated with conditions similar to those causing overflow

events, if applicable?

B. Does the City take steps needed to establish a short and long-term CIP

to address hydraulic deficiencies, including prioritization, alternatives

analysis, and schedules? Are repair and replacement projects developed

based upon condition assessment and/or field maintenance results?

YES NO

C. Does the City’s capital improvement program (CIP) establish a

schedule of approximate completion dates for both short-term and long-

term improvements and is the schedule reviewed and updated to reflect

current budgetary capabilities and activity accomplishment?

YES NO


ELEMENT 9 – MONITORING, MEASUREMENT, AND PROGRAM

MODIFICATIONS

A. Does the City maintain relevant information that can be used to

establish and prioritize appropriate SSMP activities?

YES NO

B. Does the SSMP identify and illustrate SSO trends, including frequency,

location and volume of SSOs?

YES NO

C. Is the City able to sufficiently evaluate the effectiveness of the SSMP

elements based on relevant information?

YES NO

D. Does the City update program elements, as appropriate, based upon

monitoring or performance evaluations?

YES NO


ELEMENT 10 – SSMP PROGRAM AUDITS

A. Does the audit focus on the effectiveness of the SSMP? YES NO

B. Was the SSMP Audit completed, reviewed, and filed as an Appendix to

the SSMP on a biennial basis?

YES NO


ELEMENT 11 – COMMUNICATION PROGRAM

A. Does the City communicate on a regular basis with the public and other

agencies about the development and implementation of the SSMP?

Does the communication system provide the public the opportunity to

provide input as the program is developed and implemented?

YES NO




CHANGE LOG

A. Is the SSMP Change Log current and up-to-date? YES NO


City of Lathrop SSMP Audit Report, 2016 - 2017


City of Lathrop

Sewer System Management Plan Audit Report

2016 through 2017

Date:

Prepared by:

Reviewed by:

5 March 2018

Tina Wang, P.E., EKI Environment & Water, Inc.

Jonathan Sutter, P.E., EKI Environment & Water, Inc.

Greg Gibson, P.E., City of Lathrop

Milton Daley, City of Lathrop

The purpose of the SSMP Audit is to evaluate the effectiveness of the City of Lathrop’s (City’s)

SSMP and to identify any need for improvement.

Directions: Please check YES or NO for each question. If No is answered to any question, describe

the updates/changes and the timeline to complete those changes.

INTRODUCTION

A. Is the current system description complete and up-to-date? Are

infrastructure statistics current and complete?

YES NO


The system description and infrastructure statistics reflect current conditions.

ELEMENT 1 – GOALS

A. Are the goals stated in the SSMP still appropriate and current? YES NO


Goals are appropriate and the City monitors results relevant to their goals.

ELEMENT 2 – ORGANIZATION

A. Is the Organization Chart in Figure A-1 of the SSMP current? YES NO

B. Are the position descriptions an accurate portrayal of staff

responsibilities?

YES NO

C. Is the chain of communication for reporting and responding to SSOs

accurate and up-to-date?

YES NO

D. Is the contact information in Table A-1 current? YES NO

E. Is the List of City Staff Responsible for SSMP in Table A-2 current? YES NO


No changes were needed for this element as the City’s organizational chart and staff

responsibilities are up-to-date.



ELEMENT 3 – LEGAL AUTHORITY

Does the SSMP contain current references to the Lathrop Municipal Code documenting the City’s

legal authority to:

A. Prevent illicit discharges? YES NO

B. Require proper design and construction of sewers and connections? YES NO

C. Ensure access for maintenance, inspection, or repairs for portions of the

lateral owned or maintained by the City?

YES NO

D. Limit discharges of fats, oils, and grease? YES NO

E. Enforce any violation of its sewer ordinances? YES NO

F. Were any changes or modifications made in the past two years (this audit

period) to City Sewer Ordinances, Regulations, or standards?

(discuss below)


No changes were made to the Lathrop Municipal Code that affects any of the legal authority

aspects of the SSMP.

ELEMENT 4 – OPERATIONS AND MAINTENANCE

Collection System Maps

A. Does the SSMP reference the current process and procedures for

maintaining the City’s sewer system maps?

YES NO

B. Are the City’s collection system maps complete, up-to-date, and

sufficiently detailed?

YES NO

Preventative Maintenance

C. Does the SSMP describe current preventative maintenance activities and

the system for prioritizing the cleaning of sewer lines?

YES NO

D. Are the City’s preventive maintenance activities sufficient and effective

in reducing and preventing SSOs and blockages?

YES NO

Rehabilitation and Replacement Plan

E. Is there an ongoing condition assessment program sufficient to rank the

condition of sewer pipes and schedule rehabilitation? Are the current

components of this program documented in the SSMP?

YES NO

F. Are scheduled inspections and the condition assessment system effective

in identifying, prioritizing, and addressing deficiencies?

YES NO

G. Does the rehabilitation and replacement plan include a capital

improvement plan that addresses proper management and protection of

the infrastructure assets? Does the plan include a time schedule for

implementing the short and long-term plans plus a schedule for

developing the funds needed for the capital improvement plan?

YES NO



Training

H. Does the SSMP document current training expectations and programs? YES NO

I. Do supervisors believe their staff are sufficiently trained? YES NO

J. Are the training records current? YES NO

Equipment and Replacement Part Inventories

K. Does the SSMP list the major equipment currently used in the operation

and maintenance of the collection system?

YES NO

L. Are contingency equipment and replacement parts sufficient to respond

to emergencies and properly conduct regular maintenance?

YES NO


City’s system maps are updated regularly. The preventative maintenance program descriptions

were recently updated to reflect current practices. As shown in the SSO Performance Summary,

below, the City has a small number and volume of SSOs yearly, which is indicative of an effective

maintenance program in preventing SSOs and blockages.

The City has reviewed pipe cleaning and manhole inspection statistics for the past five years and

re-assessed the cleaning frequency goal. The biennial cleaning goal has been over-aggressive for

the City’s staff resources, as the City was only able to achieve cleaning of approximately 21% of

the collection system annually during the audit period (i.e., an annual average of 12 miles out of

56 miles of gravity mains1). Considering the current rate of cleaning appears to be effective in

preventing SSOs and blockages, the City has decided to adjust the goal to complete a cleaning

and inspection cycle of every five years2, with more frequent cleaning of problem areas every two

or three months. Therefore, it is recommended that (1) the City target pipe cleaning and manhole

inspection for approximately one-third of the City’s sewer main mileage each year, (2) develop a

formal cleaning schedule, such as a map dividing the City to designated areas for annual cleaning

and illustrating problem areas for frequent cleaning, and (3) continue to maintain accurate records.

The City prioritizes rehabilitation and replacement using its own rating system based on

inspections during system flushing and CCTV inspections. During the audit period, the City

CCTV’ed approximately 9% of gravity mains during 2016, and 1% during 2017. Similar to the

pipe cleaning and manhole inspection program, the City has decided to adjust the annual CCTV

goal from 20% to 10% of the system in consideration of staff resources and that the national

average was approximately 7%3. The City may consider adopt a national standard rating system,

such as the PACP system developed by NASSCO, to score the condition of its asset.

Training on equipment and system operation is conducted on a regular basis. Training records are

1 The City currently has 72 miles of gravity mains, while only 56 miles were built before 2016. 2 Per U.S. EPA’s “Guide for Evaluating CMOM Programs at Sanitary Sewer Collection Systems”, newer

PVC systems with no significant grease contribution and reasonable slopes may last five years without

cleaning with no problems. 3 ASCE, 1999. Optimization of Collection System Maintenance Frequencies and System Performance.



maintained at the Public Works Department. The City maintains an equipment inventory list and

schedules maintenance using a CMMS system.

ELEMENT 5 – DESIGN AND PERFORMANCE PROVISIONS

A. Does the SSMP reference current design and construction standards for

the installation of new sanitary sewer systems, pump stations and other

appurtenances and for the rehabilitation and repair of existing sanitary

sewer systems?

YES NO

B. Does the SSMP document current procedures and standards for

inspecting and testing the installation of new sewers, pumps, and other

appurtenances and the rehabilitation and repair of existing sewer lines?

YES NO


No changes were needed as the City’s design and performance standards are current, appropriate,

and accurately reflected in the existing SSMP.

ELEMENT 6 – OVERFLOW EMERGENCY RESPOSNE PLAN

A. Does the City’s Overflow Emergency Response Plan (OERP) contain

proper notification procedures so that the primary responders and

regulatory agencies are informed of all sanitary sewer overflows (SSOs)

as required by the WDR and MRP?

YES NO

B. Does the OERP have a program to ensure an appropriate response to all

overflows?

YES NO

C. Does the OERP contain procedures to ensure prompt notification to

appropriate regulatory agencies and other potentially affected entities of

all SSOs that potentially affect public health or reach waters of the State

in accordance with the MRP? Does the SSMP identify the officials who

will receive immediate notification of such SSOs?

YES NO

D. Are staff and contractor personnel aware of and appropriately trained on

the procedures of the OERP?

YES NO

E. Does the OERP contain procedures to address emergency operations

such as traffic and crowd control and other necessary response activities?

YES NO

F. Does the OERP ensure that all reasonable steps are taken to contain and

prevent the discharge of untreated and partially treated wastewater to

waters of the United States and to minimize or correct any adverse

impact on the environment resulting from SSOs, including such

accelerated or additional monitoring as may be necessary to determine

the nature and impact of the discharge?

YES NO

G. Considering SSO performance data, is the OERP effective in handling

SSOs in order to safeguard public health and the environment?

YES NO



H. Is the Water Quality Monitoring Plan current and has it been trained on

and practiced by staff that would be involved in a SSO of large volume?

YES NO

I. If applicable, was sampling performed within 48 hours for all SSOs

greater than 50,000 gallons and was a Technical Report prepared and

filed on the CIWQS website?

YES NO

NA


The OERP is current and addresses WDR requirements for emergency response. City staff has

been actively referring to the OERP when responding to SSOs. As shown in the SSO Performance

Summary, below, the SSOs that occurred during the past five years were 100% contained and/or

returned. All SSOs were reported to appropriate regulatory agencies within required timelines

and uploaded to CIWQS. There has not been a major SSO requiring water sampling during the

audit period (i.e., all SSOs were less than 50,000 gallons).

ELEMENT 7 – FATS, OILS, AND GREASE (FOG) CONTROL PROGRAM

A. Does the FOG Control Program include a description of public education

outreach efforts that promote proper handling and disposal of FOG?

YES NO

B. Does the FOG program include a plan for the disposal of FOG generated

within the sewer system service area?

YES NO

C. Does the City have sufficient legal authority to prohibit discharges to the

system and identify measures to prevent SSOs and blockages caused by

FOG?

YES NO

D. Are there requirements to install grease removal devices (such as traps

or interceptors), best management practices (BMP) requirements, record

keeping, maintenance requirements and reporting requirements

established in the City’s FOG Control Program?

YES NO

E. Does the City have authority to inspect grease producing facilities and

have sufficient staff to inspect and enforce the FOG ordinance?

YES NO

F. Does the FOG control program identify sections of the collection system

subject to FOG blockages, establish a cleaning schedule and address

source control measures to minimize these blockages?

YES NO

G. Does the FOG control program implement source control measures for

all sources of FOG discharged to the collection system?

YES NO

H. Is the current FOG program effective in minimizing blockages of sewer

lines resulting from discharges of FOG to the system?

YES NO


The City has a comprehensive FOG Control Program that addresses all required items, with the

exception of a FOG disposal plan. The City itself does not generate or dispose any FOG; it

requires all FSEs to maintain copies of grease trap pumping transport manifests and make records

available for City inspection.



As shown in the SSO Performance Summary, below, the major cause for SSOs in the City is

FOG. Frequency of FOG-related SSOs varied from none to four incidences per year over the past

five years. Although the City has recently had a small number of SSOs each year, it is important

that the City continue to enforce the FOG program and frequently clean grease problem areas to

prevent future SSOs. The City currently does not have a formal procedure for obtaining and

reviewing inspection reports from the Pretreatment Coordinator (VWNA). It is recommended that

the City develop a formal process for coordinating with VWNA to regularly review FSE

inspection reports and incorporate the coordination procedure into the ERP.

ELEMENT 8 – SYSTEM EVALUATION AND CAPACITY ASSURANCE PLAN

A. Does the System Evaluation and Capacity Assurance Plan evaluate

hydraulic deficiencies in the system and provide estimates of peak flows

associated with conditions similar to those causing overflow events, if

applicable?

YES NO

B. Does the City take steps needed to establish a short and long-term CIP

to address hydraulic deficiencies, including prioritization, alternatives

analysis, and schedules? Are repair and replacement projects developed

based upon condition assessment and/or field maintenance results?

YES NO

C. Does the City’s capital improvement program (CIP) establish a schedule

of approximate completion dates for both short-term and long-term

improvements and is the schedule reviewed and updated to reflect

current budgetary capabilities and activity accomplishment?

YES NO


The City’s system evaluation and capacity assurance plan reflects conclusions from the City’s

recent Wastewater System Master Plan update. There have been no SSOs caused by hydraulic

deficiencies within the past five years.

ELEMENT 9 – MONITORING, MEASUREMENT, AND PROGRAM

MODIFICATIONS

A. Does the City maintain relevant information that can be used to establish

and prioritize appropriate SSMP activities?

YES NO

B. Does the SSMP identify and illustrate SSO trends, including frequency,

location and volume of SSOs?

YES NO

C. Is the City able to sufficiently evaluate the effectiveness of the SSMP

elements based on relevant information?

YES NO

D. Does the City update program elements, as appropriate, based upon

monitoring or performance evaluations?

YES NO




The City maintains relevant information, including SSO information and O&M statistics, to

establish and prioritize appropriate SSMP activities. Additional analyses were performed during

this SSMP audit to evaluate the effectiveness of the SSMP. It is recommended that the City

continues to track and illustrate the number of SSOs by cause, volumes, and volumes recovered.

ELEMENT 10 – SSMP PROGRAM AUDITS

A. Does the audit focus on the effectiveness of the SSMP? YES NO

B. Was the SSMP Audit completed, reviewed, and filed as an Appendix to

the SSMP on a biennial basis?

YES NO


SSMP audits were not conducted at the required biennial frequency prior to this audit. However,

the City has completed, reviewed, and filed this SSMP audit for 2016-2017 and will perform

future audits every two years. The last three audit reports will be retained as appendices to the

SSMP.

ELEMENT 11 – COMMUNICATION PROGRAM

A. Does the City communicate on a regular basis with the public and other

agencies about the development and implementation of the SSMP? Does

the communication system provide the public the opportunity to provide

input as the program is developed and implemented?

YES NO


The current SSMP and appendices are available at City Hall for public review. The City

communicates regularly with the City of Manteca per the Interjurisdictional Sewer Agreement.

CHANGE LOG

A. Is the SSMP Change Log current and up-to-date? YES NO


The change log is current and notes the major changes made during the SSMP update.

Summary of Recommendations:

This audit finds the City to be in general compliance with the WDR. Based on findings of the

audit, a summary of recommendation to further optimize system performance is provided below:

• Target pipe cleaning and manhole inspection for approximately one-third of the City’s

sewer main mileage each year;



• Develop a formal cleaning schedule, such as a map dividing the City to designated areas

for annual cleaning and illustrating problem areas for frequent cleaning;

• Consider adopt a national standard rating system, such as the PACP system developed by

NASSCO, to score the condition of pipes and manholes; and

• Develop a formal process for coordinating with VWNA to regularly review FSE

inspection reports and incorporate the coordination procedure into the ERP.



SSO PERFORMANCE SUMMARY, 2013 – 2017

The charts and tables below summarizes SSO trends over the past five years (2013-2017) based

on SSO data reported to the SWRCBs California Integrated Water Quality System (CIWQS).

The City’s average SSO rate at 3.61 SSOs/100 miles/year is below the regional average

(Region 5) at 8.76 SSOs/100 miles/year and the State average at 4.01 SSOs/100 miles/year4. The

City’s SSO rate remained low during the past five years, which some fluctuation in the number

of occurrences from year to year. The volume of City’s SSOs was very low, around 2,500

gallons in 2013 and 2016, and less than 100 gallons in 2014, 2015, and 2017. All SSO volumes

were recovered and returned to the sewer system. The cause of the City’s SSOs were mainly

FOG and debris. A total of 13 SSOs occurred between 2013 and 2017, among which six were

due to FOG deposition and four were due to debris.

These data indicate that the City has effectively addressed factors that cause SSOs and has

effectively responded to SSOs that have occurred. The City has also been successful in

protecting public health and private property in recovering as much SSO volume as possible.

4 The California Water Boards' Annual Performance Report - Fiscal Year 2015-16.

https://www.waterboards.ca.gov/about_us/performance_report_1516/plan_assess/12411_sso_sewa

ge_volume.shtml accessed 24 January 2018.

0

1

2

3

4

5

6

2013 2014 2015 2016 2017

Nu

mb

er o

f SS

Os

Total Number of SSOs

Gravity Main SSO Pump Station SSO Force Main SSO

https://www.waterboards.ca.gov/about_us/performance_report_1516/plan_assess/12411_sso_sewage_volume.shtml

https://www.waterboards.ca.gov/about_us/performance_report_1516/plan_assess/12411_sso_sewage_volume.shtml



0

500

1000

1500

2000

2500

3000

2013 2014 2015 2016 2017

Vo

lum

e o

f SS

Os

(gal

lon

s)Total Volume of SSOs

Vol of SSO Contained and/or Returned Vol of SSO Reached Surface Water

0

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2

3

4

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2013 2014 2015 2016 2017

Nu

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f SS

Os

SSO by Cause

Grease Deposition (FOG) Debris Capacity/Hydraulic Deficiency Pump Station Failure Other

APPENDIX I – Element 11 (Communication Program)

City of Lathrop Sewer System Management Plan I-1

APPENDIX I – Element 11 (Communication Program) Supporting Documents

1. Copy of Public Notifications Posted on City’s Website



Public Notification


The State Water Resources Control Board has issued Order No. 2006-0003 known as “Statewide

General WDR (Waste Discharge Requirements) For Wastewater Collection Agencies.

The order states that:

“All federal and state agencies, municipalities, counties, districts, and other public entities that

own or operate sanitary sewer systems greater than one mile in length that collect and/or convey

untreated or partially treated wastewater to a publicly owned treatment facility in the State of

California are required to comply with the terms of this Order.”

To facilitate proper funding and management of sanitary sewer systems, each Enrollee must

develop and implement a system-specific Sewer System Management Plan (SSMP). To be

effective, SSMPs must include provisions to provide proper and efficient management,

operation, and maintenance of sanitary sewer systems, while taking into consideration risk

management and cost benefit analysis. Additionally, an SSMP must contain a spill response plan

that establishes standard procedures for immediate response to an SSO in a manner designed to

minimize water quality impacts and potential nuisance conditions. One of the requirements of

the SSMP is that each Enrollee shall communicate on a regular basis with the public on the

development, implementation, and performance of its SSMP. This communication system shall

provide the public the opportunity to provide input to the collection system agency as the

program is developed and implemented.

The City of Lathrop will complete its draft SSMP in May 2009, and plans to complete the final

SSMP in July 2009. The draft SSMP is available for public review and comment on the City’s

website at the following address:

http://www.lathropgov.org/pwd/ssmp

Please provide any questions or comments regarding you may have regarding the City’s SSMP

to:

Greg Gibson


City of Lathrop Public Works Dept.

390 Towne Centre Drive

Lathrop, CA 95530

(209) 941-7430 office

(209) 941-7442 direct

(209) 941-7449 fax

e-mail: [email protected]

http://www.lathropgov.org/pwd/



Public Notification

Sewer System Management Plan, 2018 Update

The State Water Resources Control Board has issued Order No. 2006-0003 known as “Statewide

General WDR (Waste Discharge Requirements) For Wastewater Collection Agencies”. The

order requires the City to develop and implement a system-specific Sewer System Management

Plan (SSMP) to facilitate proper funding and management of sanitary sewer systems. One of the

requirements of the SSMP is that the City shall communicate on a regular basis with the public

on the development, implementation, and performance of its SSMP.

The City of Lathrop is reviewing its existing SSMP and considering revisions to the document.

The City plans to complete the update and recertify the SSMP in March 2018. A draft 2018

update to the SSMP is available for public review and comment on the City’s website at the

following address:

http://www.lathropgov.org/pwd/ssmp

Please provide any questions or comments regarding you may have regarding the City’s SSMP

update to:

Greg Gibson


City of Lathrop Public Works Dept.

390 Towne Centre Drive

Lathrop, CA 95530

(209) 941-7430 office

(209) 941-7442 direct

(209) 941-7449 fax

e-mail: [email protected]

http://www.lathropgov.org/pwd/